California Consumer Privacy Act (“CCPA”) Disclosures

Who does the CCPA apply to?

The CCPA provides certain rights to California residents.

What rights do I have under the CCPA?

Broadly speaking, the CCPA grants California residents the following rights:

1. a right to request that a business disclose the personal information that the business collects, uses, discloses and sells;

2. a right to request that a business delete the personal information that the business has collected from them;

3. a right to opt out of having their personal information sold by a business; and

4. a right not to receive discriminatory treatment by a business for exercising their rights under the CCPA

What personal information does WorkPlaceCredit/In-House Capital, LLC collect about California consumers?

The chart below describes the categories of personal information In-House Capital, LLC has collected over the past 12 months, as well as the categories of sources from which the information was collected, the business purpose for which the information is collected, and the categories of third parties with whom Personal Capital shared personal information.

Please note that we also disclose the types of information we collect earlier in our Privacy Policy.

However, the CCPA requires that we provide this information with reference to certain categories described in the CCPA and so we are restating the information here.

Category of Personal Information Examples Business Purposes
Identifiers such as 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. Categories of Sources: Y, SP, TP You provide this information when applying for a loan with In-House Capital, LLC. We may also obtain this information from service providers to verify your identity or provide services to you. 1-7
Personal information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, employment, employment history, bank account number, or any other financial information. Categories of Sources: Y, SP, TP You provide this information when applying for a loan with In-House Capital, LLC. We may also obtain this information from service providers to verify your identity or provide services to you.
We do not collect credit or debit card numbers. We do not generally collect descriptions of physical characteristics, insurance policy numbers, education, medical or health insurance information.
1-7
Characteristics of protected classifications under California or federal law. Categories of Sources: Y You may provide your age, sex, marital status and residency status when you apply for a loan with In-House Capital, LLC. 1, 2, 5-7
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Categories of Sources: Y, SP We do not collect any of this information. 1-3, 5-7
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. Categories of Sources: Y We collect your IP address and cookies from your browser to recognize you and deliver a consistent experience when you visit our site and to measure the effectiveness of our marketing. We also collect information about how you interact with our website. 1-3, 5-7
Professional or employment-related information. Categories of Sources: Y You may provide employment information when applying for a loan with In-House Capital, LLC. 2, 5
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Categories of Sources: Y We may use information you provide to tailor products or offers to you. 1, 3-7

Note that we do not collect education, biometric or geolocation information.

Categories of Sources of Information

(Y) Most of the information personal information we have is provided by you either (a) through our website, including information you enter into our web site as well as information provided by your web browser or device, or (b) when speaking to an In-House Capital, LLC customer service agent.

(SP) We receive information from service providers who help us provide services to you.

(TP) In some instances, we purchase information from third parties. For example, we may purchase addresses for direct mail campaigns and sales leads from referral partners.

Business or Commercial Purpose for Collecting the Personal Information

(1) Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

(2) Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

(3) Debugging to identify and repair errors that impair existing intended functionality.

(4) Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

(5) Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing loan applications, under writing loans, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

(6) Undertaking internal research for technological development and demonstration.

(7) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

Categories of Third Parties With Whom We Share Personal Information

We share the information described above with service providers to the extent necessary to provide the services you have requested and for the business purposes described above.

How Can I Exercise My Right to Opt Out of the Sale of My Personal Information?

In-House Capital, LLC does not sell any consumer’s personal information.

We have not sold consumer’s information in the past 12 months, except that, we allow our banking partner Cross River Bank to use the personal information that we have collected to under write loans.

How Can I Exercise My Rights Under the CCPA?

If you have an In-House Capital, LLC Loan account:

Log into your account and go to Settings.

Under the Privacy section, you will be able to request a report of the categories of information or specific information that we have collected about you or request that we delete your personal information.

In most cases, we will be able to authenticate your request using your account login.

In certain circumstances, if we believe it is necessary to authenticate your request and protect the security of your information, we may require additional information.

If you do not have a In-House Capital, LLC Loan account:

Fill out an online request form

You will need to provide your full name, phone number, and email so that we can locate you and authenticate your identity. If you previously had a In House Capital, LLC Loan account, please provide the email and phone number you used to log into your loan account.

We will authenticate your request by matching the information you provide against any information we have collected about you.

In certain circumstances, if we believe it is necessary to authenticate your request and protect the security of your information, we may require additional information.

How Can I Designate an Authorized Agent to Exercise My Rights Under the CCPA?

You may use an authorized agent to submit a request on your behalf.

To do so, the authorized agent must provide a copy of your written authorization to privacy@in-housecapital.com along with a certification that such authorization or power of attorney has not been revoked and remains in effect.

You will also be required to verify your identity directly with us.

Contact Information

If you have any questions about your rights under the CCPA, please contact privacy@in-housecapital.com.