Privacy Policy - Cashback Loans

Cashbak, LLC dba Cashback Loans Consumer Privacy Policy Notice Rev 1/2017

Cashback Loans - California Disclosures and Privacy Policy

The State of California requires that we provide privacy information for individuals that reside in California. If you do not reside in California, you can skip this document.

For California residents, here is a summary of what you will learn from this privacy policy:

1. 1. Personal Information We Collect
   • 1.1. Personal information does not include
   • 1.2. Categories of personal information we collect
   • 1.3. How we obtain your personal information
   • 1.4. How we may use your personal information
   • 1.5. How we may share your personal information
   • 1.6. Sale of personal information
   • 1.7. Additional Information for Mobile Application Users
2. 2. Your rights under the California Consumer Privacy Act of 2018
   • 2.1. Your right to request what information has been collected and how it has been used (“Right to Know”)
   • 2.2. Your right to request deletion of your personal information (“Right to Delete”)
   • 2.3. Email marketing preferences and opt-out
   • 2.4. Right to not be discriminated against for exercising your rights under the California Consumer Privacy Act (“Right to Non-Discrimination”)
3. 3. Submitting a Request to Know or Request to Delete
   • 3.1. How to submit a request
   • 3.2. Authorized agents
   • 3.3. Response timing and delivery method
4. 4. Do Not Track signals
5. 5. Changes to our privacy policy
6. 6. How to contact us

Below is the legal information we are required to share:

These California Disclosures and Privacy Policy supplements the information contained in the Privacy Notice of www.cashbackloans.com and Cashbak LLC dba Cashback Loans, Cashback Payday Advance, and Cashback (collectively, “Cashback Loans,” “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 policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California laws. Any terms defined in the CCPA have the same meaning when used in this policy.

For California residents who access or use our mobile application, this policy also applies to personal information collected through the mobile application and related mobile services.

1. PERSONAL 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 an individual consumer, device, or household (“personal information”).

1.1. Personal information does not include the following:

• Publicly available information from government records
• De-identified or aggregated consumer information
• Information excluded from the CCPA, such as 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 (DPPA)

1.2. Categories of personal information we collect:

In the last 12 months, we collected the following categories of personal information:

• “Identifiers” such as name, alias, address, unique identifier, internet protocol address, email address, account number, Social Security Number, or government identification number;
• “Other Personal Information” such as 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, or medical information. Some personal information included in this category may overlap with other categories;
• “Protected Characteristics” under California or federal law for classifications such as 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, or veteran or military status;
• “Commercial Information” such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
• “Internet or Network Activity” such as browsing history, search history, information on a consumer's interaction with a website, application, or advertisement;
• “Professional or Employment Related Information” such as Current or past job history or performance evaluations; and
• “Inferences” drawn from other personal information such as profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

1.3. How We Obtain Your Personal Information:

1.4. How We Use Your Personal Information:

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

1. 1. 1. Performing services on behalf of us or our service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of us or our service providers. This includes:
   1. To fulfill or meet the reason for which the information is provided.
   2. To provide you with information, products, or services that you request from us.
   3. To provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you.
   4. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
2. 2. Debugging to identify and repair errors that impair existing intended functionality.
3. 3. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
4. 4. Auditing related to a current interaction with the consumer and concurrent transactions.
5. 5. Undertaking activities to verify or maintain the quality of a service or device that is controlled by us, and to improve, upgrade, or enhance the service that is owned, or controlled by us.
6. 6. We may aggregate, anonymize, or de-identify personal information for use in regulatory reporting or otherwise.

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

1.5. Who We Share Your Personal Information with for a Business or Commercial Purpose:

We may disclose your personal information to a service provider or third party for a business or commercial purpose. When we disclose personal information to a service provider, we enter a contract that describes the purpose and requires the service provider to both keep that personal information confidential and not use it for any purpose except performing the contract or as otherwise allowed under the CCPA. Examples of who we share with include:

• Service providers.
• Third parties, including those to whom you or your agents authorize us to disclose your personal information in connection with the products or services we provide to you. Categories of third parties that we share personal information with are as follows:
  • With affiliates we share Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity,Professional or Employment Related Information, and Inferences;
  • With lending/bank partners we share Identifiers,Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Professional or Employment Related Information, and Inferences;
  • With credit reporting agencies we share Identifiers, Other Personal Information, Protected Characteristics, Professional or Employment Related Information, and Inferences; and
  • With advisors such as lawyers, bankers, and insurers, we share Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Professional or Employment Related Information, and Inferences.

1.6. Sale of Personal Information:

We do not sell your personal information for marketing or promotional purposes. We do not sell the personal information of minors under 16 years of age without affirmative authorization.

1.7. Additional Information for Mobile Application Users:

The following additional information applies when you use the Cashback Loans mobile application.

Information We Collect

When you use our mobile application, we may collect, receive, store, or otherwise process certain categories of information in connection with providing the application and related account services.

Account and login information. We may collect information used to identify you and provide access to the mobile application, such as your email address, username, password, session details, authentication details, and similar login-related information.

Device information. We may collect information about the device you use to access the mobile application, including device type, device model, operating system, operating system version, device identifiers, and similar technical information.

Network information. We may collect information such as your IP address and related network or connection details.

Push notification information. If push notifications are enabled, we may collect and store your device push token or similar notification identifier in order to deliver notifications through the mobile application.

Usage and activity information. We may collect information regarding your interaction with the mobile application, including screens or pages viewed, features used, button taps, timestamps, app activity, interaction logs, and similar usage or diagnostic information.

Account information from our systems. We may retrieve and display account-related information associated with your profile from our internal systems in order to provide account access, account servicing, and related functionality through the mobile application.

Uploaded documents and files. We may collect documents, images, files, and related metadata that you upload, submit, or transmit through the mobile application.

How We Collect Information

We may collect information in several ways, including:

• directly from you when you provide information, log in, use mobile application functionality, submit forms, or upload documents or files;
• automatically through your device and your use of the mobile application;
• from our internal systems and service platforms when retrieving account-related information associated with your profile; and
• through functions that support authentication, app performance, account servicing, notification delivery, security, and operational support.

How We Use Information

We may use the information we collect through the mobile application for business, operational, servicing, and legal purposes, including to:

• authenticate users and provide secure access to the mobile application;
• provide, maintain, operate, and improve the mobile application;
• display account, servicing, and profile-related information within the mobile application;
• process documents, files, and requests submitted through the mobile application;
• send push notifications, alerts, account-related messages, and service communications;
• monitor usage, performance, stability, and reliability of the mobile application;
• detect, investigate, prevent, and respond to fraud, misuse, unauthorized access, security incidents, and other harmful or unlawful activity;
• provide customer support, troubleshoot issues, and respond to inquiries; and
• comply with applicable legal, regulatory, compliance, audit, and recordkeeping requirements.

How We Share Information

We may share information collected through the mobile application with our affiliates, subsidiaries, service providers, contractors, and other third parties that perform functions on our behalf or support the operation of the mobile application. These parties may include providers of hosting, infrastructure, storage, authentication, backend processing, analytics, notification delivery, customer service, document handling, and security services.

We may also disclose information where necessary or appropriate to comply with applicable law, regulation, legal process, or governmental request, to protect our rights and property, to protect the security and integrity of our systems and mobile application, or to protect the safety of our users, customers, employees, or others.

Data Retention

We retain information collected through the mobile application for as long as reasonably necessary to provide the mobile application and related services, fulfill the purposes described in this Privacy Policy, comply with legal or regulatory obligations, resolve disputes, enforce our agreements, protect our business interests, and maintain appropriate business and operational records.

Certain information, including account-related records, uploaded documents, technical logs, and servicing-related information, may be retained for longer periods where required or permitted by law, regulation, legal process, fraud prevention, security, audit, compliance, or legitimate business purposes.

Deletion Requests

If you maintain an account through our mobile application, you may request deletion of your account and associated personal information through the deletion request functionality made available within the mobile application or through our designated support or contact channels.

As part of the deletion request process, we may request information necessary to verify your identity and process your request. We may also allow you to provide a reason for the request for internal tracking, customer support, compliance, and operational purposes.

Once a deletion request is submitted, we may acknowledge receipt of the request and process it in accordance with applicable law, regulatory obligations, operational requirements, and our retention practices. Certain information may be retained where necessary for legal compliance, fraud prevention, dispute resolution, enforcement of agreements, security purposes, servicing records, or other legitimate business needs.

Push Notifications

If you choose to enable push notifications, we may send notifications related to your account, servicing activity, reminders, updates, alerts, and other service-related communications. You may manage or disable push notifications through your device settings, subject to the functionality of your device and operating system.

2. YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT OF 2018

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.

2.1. Right to Know:

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 (“Request to Know”). Once we receive and verify your request, we will disclose to you:

• Categories of Personal Information Collected and Shared
  • 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 personal information.
  • The categories of third parties with whom we share that personal information.
  • If we disclosed your personal information for a business or commercial purpose, the categories of personal information shared with each category of recipients.
• Specific Information
  • The specific pieces of personal information we collected about you.

We may deny your Request to know if we are unable to verify your identity or have reason to believe that the request is fraudulent. We may also deny your request if the personal information is subject to an exemption under the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), or the Driver's Privacy Protection Act of 1994 (DPPA).

2.2. Right to Delete:

You have the right to request that we delete any of your personal information that we collected and retained, subject to certain exceptions (“Request to Delete”). Once we receive and verify your request, we will delete, de-identify, or aggregate your personal information (and direct our service providers to do the same), unless an exception applies.

For California residents who maintain an account through our mobile application, a deletion request may also be initiated through the deletion request functionality made available within the mobile application, where applicable. Submission of a request through the mobile application does not limit our ability to verify your identity or retain information where permitted or required by law.

We may deny your Request to Delete if retaining the personal information is necessary for us or our service providers to:

• Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business's ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
• 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 businesses' deletion of the information is likely to render impossible or seriously impair the achievement of such research if the consumer has provided informed consent.
• To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer's relationship with the business.
• Comply with a legal obligation.
• Otherwise use the consumer's personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
• The personal information is subject to an exemption under the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), or the Driver's Privacy Protection Act of 1994 (DPPA).

Additionally, we may deny your Request to Delete if we are unable to verify your identity or have reason to believe that the request is fraudulent.

2.3. CCPA Right to Opt-Out:

The CCPA gives consumers the right to opt-out of the sale of their personal information. However, we do not sell your personal information for marketing or promotional purposes. We do not sell the personal information of minors under 16 years of age without affirmative authorization.

Disclosure: “No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties."

2.4. Non-CCPA Email Marketing Preferences and Opt-Out:

You may opt-out of our email marketing by using the general unsubscribe automated link that is included in marketing emails. If you have any problems using this opt-out mechanism, please use the contact form accessible at www.cashbackloans.com.

2.5. Right to Non-Discrimination:

Your have the right to not be discriminated against for exercising your rights under the CCPA. Unless permitted by the CCPA, we 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.

3. SUBMITTING A REQUEST TO KNOW OR REQUEST TO DELETE

3.1 How to submit a request:

To make a Request to Know or Request to Delete, please contact us by either:

• Calling us at 760-600-5639
• Emailing us at privacypolicy@cashbackloans.com
• Submitting a deletion request through the deletion request functionality available within our mobile application, where applicable.

If a deletion request is submitted through the mobile application, we may request additional information as necessary to verify your identity and process your request.

Only 1) you, 2) a person authorized by you to act on your behalf, or 3) an entity registered with the California Secretary of State and authorized by you to act on your behalf, may make a Request to Know or Request to Delete your personal information. You may also make a request on behalf of your minor child.

You may only make a Request to Know twice within a 12-month period.

A Request to Know or Request to Delete must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collect personal information or an authorized representative. Given the sensitivity of your personal information that we collect and retain, we will need to verify your identity with at least 3 separate pieces of information such as name, address, account number, date of birth, last 4 of your Social Security Number, valid government-issued ID, phone number, etc.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• If you are submitting a Request to Know specific pieces of personal information, then you will also need to submit a declaration under the penalty of perjury confirming that you are only requesting information about yourself.

3.2. Authorized Agents:

Before we can respond to a Request to Know or Request to Delete submitted by an authorized agent, we need to confirm not only that person or entity’s authority to act on your behalf but also verify the identity of the authorized agent.

If you are authorized to submit a request on behalf of a California resident, please email us at privacypolicy@cashbackloans.com and provide the following information:

1. 1. To verify your authority to request on behalf of a California resident, please attach a copy of one or more of the following to your request email:
   • California Secretary of State “entity details” and written permission (if the authorized agent is a business entity),
   • written permission from the California resident, or
   • power of attorney
2. 2. To verify your identity, please attach copies of the following to your request email:
   • Valid Government Issued ID (not expired) AND
   • a Utility Bill, Bank Statement, or similar documentation to verify your name and address.
3. 3. To verify the identity of the consumer for whom you are submitting the request, please attach two or more of the following with your request email (three or more are required when requesting a copy of the California resident’s personal information):
   • Valid Government Issued ID (not expired),
   • utility bill,
   • bank statement,
   • Email address,
   • last 4 of the SSN or
   • last 4 of the account number

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

3.3. Response Timing and Delivery Method:

We will acknowledge receipt of a Request to Know or Request to Delete within 10 business days. We will respond to a 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. 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 our receipt of the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For Requests to Know specific pieces of information, we will provide the responsive information in a portable and, to the extent technically feasible, in a readily usable format that allows you to transmit the information to another entity without hindrance.

We do not charge a fee to process or respond to your 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.

4. DO NOT TRACK SIGNALS

Our site does not respond to Do Not Track signals configured in your web browser.

5. CHANGES TO OUR PRIVACY POLICY

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

6. HOW TO CONTACT US

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

You may also contact us through the support channels made available within our mobile application, where applicable.

Version 2.0 – Effective Date 9/14/2020