Additional California Privacy Disclosures
Last Updated: Jun 27, 2023
Additional California Privacy Disclosures
These Additional California Privacy Disclosures (the “Disclosures”) supplement the information contained in our Privacy Notice and apply solely to individual residents of the State of California (“consumers” or “you”).
These Disclosures describe how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018, as amended and/or supplemented (“CCPA”). For a detailed description of how we collect, use, disclose, and otherwise process personal information in connection with our services, please visit our Privacy Notice.
With a limited exception, certain provisions of the CCPA do not apply to Personal Information covered by or collected under industry-specific privacy laws including but not limited to:
- The Gramm-Leach-Bliley Act (certain financial information privacy laws),
- The California Financial Information Privacy Act (certain financial information privacy laws),
- The Fair Credit Reporting Act (information relating to your credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, and mode of living), and
- The Driver’s Privacy Protection Act of 1994.
Unless otherwise expressly stated, all terms in these Disclosures have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.
What is Personal Information
When we use the term “personal information” in these Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include aggregated or deidentified information that is maintained in a form that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular consumer or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.
Collection and Use of Personal Information
As described in more detail in the Our Collection and Use of Personal Information section of our Privacy Notice , we collect the following categories of personal information:
- Identifiers, including full name, email address, and IP address.
- Customer Records, including home address, business address, and phone number.
- Commercial Information, including transaction information.
- Internet/Network Information, including log data and analytics data.
- Geolocation Data, including general geographic location or more precise location to the extent permitted by law.
- Sensory Information, including, where permitted by law, recordings of phone calls between us and individuals, and audio, image, and video recordings of visitors to our offices or events.
- Profession/Employment Information, including your employer, company name or the name you are doing business as, your business’s contact information, your job title or description, length of employment, real estate experience, company affiliations, trust affiliations, professional licenses and license status, relevant education, and diligence information.
- Other Personal Information, including personal information you permit us to see when interacting with us through social media, and personal information you provide us in relation to your questions, requests, or inquiries.
- Inferences, including our predictions about interests and preferences based on other personal information we have collected about you.
Sources of Personal Information
As described in the Our Collection and Use of Personal Information section of the Privacy Notice , we collect personal information directly from you when you provide it to us, automatically when you visit our website, and from credit bureaus, state licensing agencies, service providers, publicly available sources and other third parties.
Purposes for Collecting Personal Information
We collect personal information about you for the purposes described in the Our Collection and Use of Personal Information section of the Privacy Notice .
Purposes for Collecting Personal Information
We collect personal information about you for the purposes described in the Our Collection and Use of Personal Information section of the Privacy Notice.
Disclosure, Sale, and Sharing of Personal Information
As described in the Our Disclosure of Personal Information section of the Privacy Notice, we may disclose all of the personal information identified above to third parties for business purposes. The categories of third parties to whom we disclose personal information for these purposes include our parent company, Redwood, and our family of companies, businesses you represent, transaction partners, data analytics providers, marketing partners, vendor management providers, service providers, and certain other third parties where you have provided consent, we are engaging in a business transaction or reorganization, or we are addressing our legal obligations and rights.
As is common practice among companies that operate online, we allow certain third-party providers to use cookies and related technologies to collect log data, analytics data, and location information about consumers directly through our website for purposes of analyzing and optimizing our services, delivering ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. Some of these practices may constitute the sale of personal information or the use of personal information for the purpose of displaying advertisements that are selected based on personal information obtained or inferred over time from an individual’s activities across businesses or distinctly branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”). Subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal information or the sharing of personal information for purposes of targeted advertising (as described in the Your California Privacy Choices section below).
However, we do not otherwise sell personal information or share personal information for purposes of targeted advertising. In addition, we do not sell sensitive information or share sensitive information for purposes of targeted advertising, nor use sensitive information for the purpose of inferring characteristics about a consumer in a manner that would require our offering of the right to limit the use of such information.
Retention of Personal Information
We retain personal information only for as long as is reasonably necessary to fulfil the purpose for which it was collected. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax, or accounting requirements set by a legislature, regulator, or other government authority.
To determine the appropriate duration of the retention of personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, and whether we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.
Once retention of the personal information is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal information or, if this is not possible (for example, because personal information has been stored in backup archives), then we will not further process the personal information until deletion or deidentification is possible.
Your California Privacy Choices
As a California resident, you may be able to exercise the following rights (subject to certain limitations at law):
The Right to Know |
The right to confirm whether we are processing personal information about you and to obtain certain personalized details about the personal information we have collected about you, including:
|
The Right to Access & Portability |
The right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. |
The Right to Correction |
The right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information. |
The Right to Opt-Out of Targeted Advertising |
The right to direct us not to share personal information for certain cross-context behavioral or targeted advertising purposes. |
The Right to Opt-Out of Sales |
The right to direct us not to sell personal information we have collected about you to third parties. |
The Right to Request Deletion |
The right to have us delete the personal information we have collected from you. |
The Right to Know |
The right to confirm whether we are processing personal information about you and to obtain certain personalized details about the personal information we have collected about you, including:
|
The Right to Access & Portability |
The right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. |
The Right to Correction |
The right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information. |
The Right to Opt-Out of Targeted Advertising |
The right to direct us not to share personal information for certain cross-context behavioral or targeted advertising purposes. |
The Right to Opt-Out of Sales |
The right to direct us not to sell personal information we have collected about you to third parties. |
The Right to Request Deletion |
The right to have us delete the personal information we have collected from you. |
You also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, please note that if the exercise of these rights limits our ability to process personal information, we may no longer be able to engage with you in the same manner.
Submitting Privacy Requests
To Exercise the Right to Know, Access, Portability, Correction, or Deletion
To submit a request to exercise the right to know, access, portability, correction, and/or deletion, please submit a request specifying the right you wish to exercise by:
- Submitting this form via our website, or
- Calling us at 1-866-221-3171.
Before processing your request, we will need to verify your identity and confirm you are a resident of California. As a result, we require requests to include:
- The full name of the individual the personal information is about (the consumer);
- The full name of the individual making the request and their relationship to the consumer;
- The consumer’s address, including the state of residency;
- The consumer’s relationship to Aspire and the products and/or services relevant to the request;
- The right to be exercised, the associated request and the scope of personal information involved (e.g., all or a subset of the information); and
- The best phone number or email address for us to contact the requesting individual and the consumer.
In order to verify your identity, we may also require additional personal information to match against the information we maintain about you in our systems.
In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or confirm you are a resident of California.
To Exercise the Right to Opt Out of Personal Information Sales or Sharing for Targeted Advertising Purposes
We allow certain third-party providers to use cookies and related technologies to collect information about consumers directly through our website in a manner that may constitute either a sale of personal information or the processing of personal information for purposes of targeted advertising. To exercise the right to opt out of these practices, please click the green cookie icon in the lower left-hand corner of your screen to utilize the Cookie Preferences plugin on our website to adjust your preferences. In addition, you may follow the other steps set forth in the Cookies and Related Technologies section of our Privacy Notice to further exercise control over cookies and related technologies used in connection with these practices.
Although we do not otherwise sell personal information or share personal information for targeted advertising purposes, it is possible that we may engage in data transfers that constitute a sale or sharing for targeted advertising purposes in the future. To exercise the right to be added to our opt out list in the event of future sales or sharing for targeted advertising purposes, please complete the form here or call us at 1-866-221-3171.
Please include with your request the information described in the To Exercise the Right to Know, Access, Portability, Correction, or Deletion section above. Once you make an opt-out request, you may change your mind and opt back in to personal information sales or sharing for targeted advertising purposes at any time by contacting us at [email protected].
Minors Under Age 16
We do not sell the personal information of consumers we know to be less than 16 years of age or share such information for targeted advertising purposes, unless we receive affirmative authorization (the “right to opt-in”) from either a minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at [email protected] to inform us if you, or your minor child, are under the age of 16 and have provided us with personal information.
Submitting Authorized Agent Requests
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.
