This Privacy Policy for California Residents applies solely to all 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 any terms defined in the CCPA have the same meaning when used in this Policy.

This Policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. Company employees are directed to Athas Capital Group’s CCPA Notice at Collection for California Employees and Applicants.

Where noted in this Policy, the CCPA currently exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information“) from some of its requirements.

Information We Collect

We collect 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“). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • 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), clinical trial data, or other qualifying research data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we may have collected some or all of the information from the following categories 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. 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. YES
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. 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

We obtain 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 a third party acting on your behalf.

Use of Personal Information

We may use or share or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • To provide, support, personalize, and develop products, and services.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our products, and services.
  • To 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.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.

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 may share your personal information by disclosing it to a third party for a business purpose. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell personal information. We may share the Personal Information above with the following parties:

  • Affiliates
  • Subsidiaries
  • Business partners
  • Service providers
  • Consumer reporting agencies
  • Third parties with whom you authorize or direct us to share your information
  • To comply with legal requirements, including, but not limited to, regulatory, court, and law enforcement demands (e.g., subpoenas, court orders, etc.)
  • To address fraud, security or technical issues; and
  • To respond to an emergency or otherwise to protect the rights, property or security of our company, customers or third parties
  • Third parties or affiliates in connection with a corporate transaction, such as a sale, consolidation or merger of Company’s businesses

Your Choices About Your Information

Information we collect from or about individuals in connection with providing a lending product is treated in accordance with applicable federal and state privacy laws including the Gramm-Leach-Bliley Act (GLBA) and Fair Credit Reporting Act (FCRA). We therefore use and share any information that we collect from or about consumers of our financial products or services consistent with the disclosures in our Consumer Privacy Notice, posted here. We do not generally maintain personal information about individuals other than in connection with lending activities, and therefore consumer disclosure and deletion requests as specifically provided by the California Consumer Privacy Act (CCPA) are not applicable.

Accessing and Correcting Your Information: Keeping your account information up-to-date is very important. You may review or update certain account information and transactions by contacting us.

Emails: In all promotional emails, you will be given the opportunity to opt-out of receiving such messages in the future by clicking on the link at the bottom of the email that says “unsubscribe.” It may take up to ten (10) business days for us to process your opt-out request. Please note that even after opting out of promotional emails, we may still send you customer service announcements, administrative notices and services-related communications (e.g., account notices, transaction confirmations, and security notices).

Text messages: In the event you are enrolled in any service that provides text messages to you, you can opt-out of receiving text messages from that service by replying “STOP” to any text message received. You will continue to receive text messages from product lines or services from which you have not opted out.

Mobile devices: Mobile devices may allow a user to block certain information requests (e.g., location information), but doing so may diminish your experience with our services. Mobile device or mobile operating system providers typically provide instructions on how to adjust such privacy features.

We do not provide a financial incentive or a price or service difference to customers in exchange for the retention or sale of their personal information. We may send promotions or offers to customers or other individuals who subscribe to marketing communications, and unless a customer has opted out of such communications, the customer will continue to receive such notices irrespective of whether any information privacy request described here has been submitted. We do not offer financial incentives to deter customers from making such requests. We do not discriminate against any customer for exercising any privacy rights, including those provided by applicable laws.

We do not respond to Do Not Track (DNT) signals and handle all user information as permitted by law consistent with our Terms of Use and this Online Privacy Policy. Other parties may not collect personal information about an individual’s online activities over time and across different websites when using our services.

Linking to Third-Party Websites

Our website may contain links to other websites, services or social media platforms owned or operated by other companies (“Third-Party Websites”). Third-Party Websites are not subject to our Privacy Policy. We are not responsible for the practices employed by any Third-Party Websites or services linked to or from our Services, including the information or content contained within them. Your browsing and interaction on any Third-Party Websites or service, including those that have a link on our website, are subject to that third party’s own rules and policies, not ours. By accessing Third-Party Websites, you agree that we are not responsible and do not have control over any third parties that you authorize to access your personal information, which includes your sharing of account credentials with any third party or linking your activity to any social media platforms or data aggregators.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we update this privacy policy, we will post the updated notice on the 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.

Contact Information

If you have any questions or comments about this notice, the ways in which Company collects and uses your information described here, 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: (855) 519-0200

Email: privacy@athascapital.com

Postal Address:

Athas Capital Group, Inc.

Attn: Privacy Department

27001 Agoura Rd Suite 200, Calabasas Hills, CA 91301

If you need to access this Policy in an alternative format due to having a disability, please contact privacy@athascapital.com or (855) 519-0200.

Effective Date

This Privacy Policy was last revised and is effective as of May 1, 2022.