Privacy Statement - California

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of Channel Partners Capital, LLC and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples Collected
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. NO
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. NO
G. Geolocation data. Physical location or movements. NO
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employmentrelated information. Current or past job history or performance evaluations. NO
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. NO
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

Personal information does not include:

1. Publicly available information from government records.
2. De-identified or aggregated consumer information.
3. Information excluded from the CCPA’s scope, like:
a. health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
b. personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

Information Provided by You. We collect any information you provide when you use the Services. For example, we collect User Information and Business Information from you when you (i) register an account on the Sites, (ii) fill out forms or fields on the Sites, or (iii) complete an application for a product or service available through the Services. We also collect any information you may submit through communications with us by email, mail, text, telephone, facsimile or other means. The Services allow us, upon your direction, to obtain User Information and Business Information from third party entities that your business maintains accounts with such as financial institutions, service providers, and social networking services. For example, we may obtain (i) transactional information about your business from financial institutions, (ii) information about your business’s engagement with customers from social networking services, and (iii) information about your business’s sales volume from service providers.

Information We Collect When You Use Our Services. We automatically collect General Information from your computer, mobile device or other device you use when you access the Services (including downloading and using a mobile application or accessing a mobile optimized Site), view content about the Services on a third-party website or open emails or links in emails from us. We, our business partners, or our service providers may use cookies or similar technologies to collect information. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services. Please review your web browser “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Services to their fullest potential. We also use cookies and similar technologies hosted by third parties on the Services.

Information Received from Third Parties. In the course of providing the Services, we may also collect additional Business Information or User Information from third parties, including, but not limited to: financial institutions, referral partners, identity verification services, card networks, vendors, mailing list providers, consumer reporting agencies, commercial credit bureaus and associations, fraud prevention agencies, and publicly available sources. We may combine this information with information we already have about you.

Use of Personal Information

Service-Related Usage. We use the information we collect about and from you, both in a personally identifiable form and in an aggregated or anonymized form, for a number of purposes, including for providing, supporting, promoting, and improving the Services. Such uses include:

a. Enabling users to obtain products and services through the Services;
b. Facilitating marketing, processing, servicing, and collections activities;
c. Providing customer support;
d. Understanding, customizing, and enhancing user experience;
e. Providing targeted marketing and advertising;
f. Determining your eligibility for the Services;
g. Verifying your identity, conducting appropriate diligence, and keeping your information current;
h. Creating an account connection between your account and a third-party account or platform;
i. Sending notifications and information regarding the Services;
j. Measuring and improving the performance and functionality of the Sites;
k. Managing and protecting our information technology infrastructure;
l. Administering and managing the security of the Sites;
m. Developing new products and services; and
n. Compiling, using, researching, analyzing, and generating data analytics reports to better understand our Customers and to improve the Services;

Communications. We may communicate with you using the information collected (i) for customer service, (ii) to provide you with updates or information relating to the Services, or (iii) to conduct surveys and collect feedback about the Services.

Marketing and Advertising. We may use the information we collect for marketing and advertising purposes, such as providing you with promotional materials that may be useful, relevant, valuable, or otherwise of interest to you. Where required under applicable law, we will obtain your prior opt-in consent to send you electronic marketing communications. To learn more about your choices regarding interest-based advertising and cross-device tracking, please see the Third-Party Information Collection section below.

Compliance with Law and Our Own Obligations. We may use the information we collected, to the extent permitted or required under applicable laws (i) to detect and protect against potentially prohibited or illegal activities, including fraud and unauthorized access, (ii) in response to lawful requests for information or legal process, (iii) to establish, exercise, or defend a legal claim, and (iv) to comply with our contractual obligations, our policies, industry standards, and applicable laws.

Other Purposes. We may use the information we collect for other purposes for which we provide notice to you at the time of collection or for which we obtain your consent.

Aggregate Data. We may process your information in an anonymized or aggregated form for purposes other than described above.

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.

Sharing Personal Information

We will not disclose your personal information to a third party.

Your Rights and Choices

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.

Access to Specific Information and Data Portability Rights.

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

1. The categories of personal information we collected about you.
2. The categories of sources for the personal information we collected about you.
3. Our business or commercial purpose for collecting or selling that personal information.
4. The categories of third parties with whom we share that personal information.
5. The specific pieces of personal information we collected about you (also called a data portability request).
6. If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
a. sales, identifying the personal information categories that each category of recipient purchased; and 
b. disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

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.

We may deny your deletion request if retaining the information is necessary for us or our service providers 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, 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 seq.).
6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
7. Comply with a legal obligation.
8. 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 us by either:

1. Calling us at (763) 746-7760
2. Visiting our website www.channelpartnerscapital.com

Only you or a person registered with the California Secretary of State that you authorize 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:

1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
2. Describe your request with sufficient detail that allows us 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 the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. 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

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 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 the verifiable consumer request’s receipt. 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 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

1. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: 2. Deny you goods or services. 3. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. 4. Provide you a different level or quality of goods or services. 5. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (763) 746-7760
Website: www.channelpartnerscapital.com
Email: media@channelpartnersllc.com

Postal Address:
Channel Partners Capital, LLC
11100 Wayzata Boulevard, Suite 305
Minnetonka, MN 55305