California Privacy Disclosures

Last Updated: February 1, 2020

For more information about what we do with consumer information if you are not a resident of California, please refer to our Privacy Policy. Herein, we provide you with additional information in these California Privacy Disclosures (“CA Disclosures”) about how, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”), Start New Settlement, LLC d/b/a Start New Financial (“Start New,” “we,” “us” or “our”) uses, discloses collects and otherwise processes the personal information of individual residents of the State of California.

The meaning provided by the CCPA is what “personal information” has here for the purposes of these CA Disclosures and does not include information that is aggregated, that is de-identified or publicly available, such that it is not capable of being associated with an individual, information relating to our contractors, employees, job applicants or other personal information, or information that is excluded from the CCPA’s scope, such as personal information covered by certain sector-specific federal privacy laws, including GLBA, HIPAA, FCRA or the Driver’s Privacy Protection Act of 1994. Please review our Privacy Policy to understand how, in connection with financial services and products, we process personal information.

Collection and Use of Personal Information

Start New is an institution that is subject to privacy provisions as described in the Gramm-Leach-Bliley Act ("GLBA"). Section 1798.145(e) of the CCPA does exempt personal information collected by a covered institution pursuant to the GLBA. Accordingly, much, if not all, of the data consumers provide to Start New, or that we collect from consumers, will fall within the GLBA exemption to the CCPA's definition of personal information and thus outside the scope of the CCPA.

Start New recognizes the eleven (11) broad categories of personal information referenced in the CCPA that a business may collect about a consumer. In particular, Start New has collected the following categories of personal information from consumers within the last twelve (12) months (though most, if not all, such personal information is collected pursuant to the GLBA and is thus exempt from the CCPA):

Personal information does not include publicly available information from government records, de-identified or aggregated consumer information, or information otherwise excluded from the CCPA's scope, such as information collected pursuant to the GLBA. Any personal information or category of personal information collected pursuant to the GLBA would not be considered "personal information" under the CCPA.

Notwithstanding the GLBA exemption to which most, if not all personal information collected by Start New is subject, we have obtained the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from information we obtain in the course of providing our services to you, or from observing your actions on our website.
• From third-party business partners such as social media sites, ad networks, and analytics providers.

Start New may use this information to:

• Provide you with the information, products, or services you request from us.
• Fulfill the reason you provided the information, such as to respond to customer service requests or other inquiries.
• Create, maintain, customize, and secure your account with us.
• Personalize your website experience and 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).
• Help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
• Process your requests, purchases, transactions, and payments
• Provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
• Prevent transactional fraud.
• 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.

Start New will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing notice to you. Such notice may be delivered, for example, by posting an updated California Privacy Notice.

Sharing Personal Information

Start New may disclose your personal information to a third party for business purposes. When we do so, Start New  enters into a contractual arrangement that describes the business purpose and requires the recipient to both: (A) keep that personal information confidential; and (B) not use it for any purpose except performing the obligations under the contract.

We share your personal information with the following categories of third parties for a business purpose:

• Affiliates.
• Service providers.
• Data aggregators.
• Social media companies
• Internet cookie data recipients (e.g., Google analytics)

Disclosure of Personal Information for a Business Purpose

The CCPA requires Start New  to provide you with a statement on its personal information disclosures for a business purpose that reference the eleven (11) categories of information reflected in the chart above. In the preceding twelve (12) months, Start New  has disclosed the following categories of personal information 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.

Sale of Personal Information

The CCPA similarly requires Start New  to provide you with a statement on its personal information sales. In the preceding twelve (12) months, Start New  had not sold your personal information. Start New  does not and will not sell personal information of California consumers.

Notice Regarding Your Rights

Access & Data Portability Rights
You have the right to request that Start New disclose what personal information we collect, use, and disclose. If we receive and confirm your consumer request as verifiable and no exception applies, we will provide you with:

• 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 that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you.
• If we sold or disclosed your personal information for a business purpose, two lists disclosing:
• Sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

As previously indicated, Start New does not sell the personal information of California consumers.

Deletion Request Rights

Subject to certain exceptions, you have the right to request that we delete any of your personal information that we collected from you and retained. If we receive and confirm your consumer request as verifiable, unless an exception applies we will delete (and direct our service providers to delete) your personal information from our records.

The CCPA provides a number a reasons why a deletion request may be denied. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Start New by:

• Calling us toll-free during business hours at (800) 320-9083.
• Filling out the California Consumer request and send it to [email protected]
• Submitting a request through your online account.

Only you or someone registered with the California Secretary of State and legally authorized to act on your behalf may make a verifiable consumer request related to your personal information.

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

The verifiable consumer request must:

• Provide sufficient information that allows Start New to verify, to a reasonable degree of certainty, that you are the person about whom Start New collected personal information (or your authorized representative), which may include multi-factor authentication of identifying information provided by you. Such authentication may be conducted and verified independently or in combination with a comparison of personal information already maintained by Start New, if any; and
• Describe your request with sufficient detail that allows Start New to properly understand, evaluate, and respond to it.

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 that the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us, but we must also be able to confirm the personal information relates to you. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

Start New endeavors to respond to a verifiable consumer request within forty-five (45) days of receiving it. If Start New requires additional time to process your request, up to a maximum total of ninety (90) days from the date the request is received, we will notify you of this and inform you of the reason for requiring the additional time.

If you have an online account with us, we will deliver our written response to your online 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 the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request or have denied a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination
Start New will not discriminate against you for exercising any of your CCPA rights as described above. Unless permitted by the CCPA, Start New 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 may receive a different price or rate for goods or services or a different level or quality of goods or services.

Do Not Track Disclosures

• How do we respond to Web browser "do not track" signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer's online activities over time and across third-party websites or online services?
  We currently do not respond to DNT signals in browsers because we do not track individual users across the web.
• May other parties collect personally identifiable information about an individual consumer's online activities over time and across different websites when they visit www.startnewfinancial.com?
  No.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits certain individuals that are California residents to request information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please email us at or write to us at Start New Financial, LLC, 5366 Plainfield Ave NE Suite B Grand Rapids, MI 49525.

Changes to Our Privacy Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on our website and update the Notice's effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.