Effective Date: 03-March-2022
We collect information in multiple ways, including when you provide information directly to us, and when we passively collect information from you, such as from your browser or device that you use to access our Website.
When you use our Website, we may collect personal information about you, such as your name, address, Social Security number, telephone number, email address, asset information, income information, or any other information that you submit on applications or other forms made available through the Website.
We use the personal data we collect for purposes described in this Policy or otherwise disclosed to you. For example, we may use any of the above categories of data as applicable to:
Processing applications and transactions;
Verifying your identity (such as when you access your account information);
Supplementing personal information we have for purposes such as maintaining and correcting our records, adding supplemental data fields, and verifying the identity of applicable persons and companies
Responding to your requests and communicating with you;
Managing your preferences;
Performing analytics concerning your use of our online services, including your responses to our emails and the pages and advertisements you view;
Providing you tailored content and marketing messages;
Providing support and customer service;
Operating, evaluating and improving our business; and
Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies
We may also use data that we collect on an aggregate or anonymous basis (such that it does not identify any individual customers) for various business purposes, where permissible under applicable laws and regulations.
We may share the information we collect about you with third parties, such as companies performing services on our behalf to provide the products or services you have requested. We may also share information collected about you with companies with whom we have formal agreements to offer you financial products and services as well as with our affiliates and with nonaffiliates for analysis, market research and marketing purposes as allowed by law. Finally, we may disclose your personal information as otherwise permitted or required by law.
We take technical, administrative, and physical measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, or unauthorized access. By using our Website, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through, or on our Website and that any such transmission is at your own risk. If you have any questions about the security of your information, you can contact us at [email protected].
Our websites are not intended for children under the age of 13. We do not knowingly collect or maintain personal information about children under the age of 13 unless the personal information is provided by a parent, legal guardian or authorized adult.
We keep your personally identifiable information for no longer than necessary and/or as required to comply with applicable laws. The length of time for which we retain information depends on the purposes for which we collected and use it.
We reserve the right to change this Policy at any time to reflect changes in the law, our data collection and use practices, the features of the Website, or advances in technology. Please check this page periodically for changes. Your continued use of the Website following the posting of changes to this Policy will mean you accept those changes. If we make any material changes to our data privacy practices, we will notify you in accordance with applicable legal requirements.
This California Consumer Privacy Act Disclosure (“CCPA Disclosure”) explains how Splitero collects, uses, and discloses personal information subject to the California Consumer Privacy Act (“CCPA”). It also describes the privacy rights of California residents under the CCPA and how they can exercise those rights.
This CCPA Disclosure applies solely to California residents and supplements any other privacy policies or notices applicable to the Splitero services that you visit or use.
What Personal Information Is Covered by the CCPA?
Under the CCPA, “personal information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.The CCPA does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, and certain other state or federal privacy laws. This CCPA Disclosure also does not apply to information that we collect in connection with providing products or services to other businesses or when receiving products or services from our suppliers.
What Information Is Collected?
We collect and have collected, used, and disclosed, in the past twelve (12) months, the following categories of Personal Information about California residents:
Identifiers such as full name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, account title, Social Security number, driver’s license number, passport number, or other similar identifiers;
Personal Information as defined in the California safeguards law such as driver’s license or state identification card number, bank account number, debit card number, or any other financial information;
Protected classification characteristics under California or federal law such as age, citizenship, physical or mental disability, 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 other electronic network activity or information such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement; Geolocation data such as physical location or movements;
Sensory data such as audio, electronic, or similar information;
Professional or employment-related information; and
Inferences drawn from other personal information which may include a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We collect the above categories of Personal Information from the following sources:
From California residents or authorized agents and parties (e.g., from documents that you provide to us related to the services for which you engage us or through information we collect from you including your employer, in the course of providing services to you);
Directly and indirectly from your activity on our digital properties (e.g., from submissions through our website portal or website details we collect automatically);
From third parties (e.g., credit bureaus and consumer data resellers) that interact with us in connection with services and activities we perform; and
From our affiliates.
We collect and have collected in the past twelve (12) months the above categories of Personal Information for one or more of the following business or commercial purposes:
To fulfill or meet the reason for which the information was provided or related products and services. If you provide your personal information to purchase a product or service, we will use that information to process your request;
To provide, support, and develop our websites, products, and services;
To create, maintain, customize, and secure your account with us;
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 response;
To personalize your website experience and to deliver relevant content and product and service offerings, including targeted offers and ads through our websites, 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 business websites, products and services, databases and other technology assets;
For testing, research, analysis, and product development, including to develop and improve our websites, products, and services;
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; and
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
Sharing of Personal Information
We disclose the above categories of your Personal Information to third parties for business purposes or as required or permitted by law including with our affiliates and subsidiaries, service providers, third parties to whom you authorize us, directly or indirectly, to disclose your personal; information in connection with products or services we provide to you and government or regulatory authorities, as required by law.
Sale of Personal Information
In the preceding twelve (12) months, we have not sold or otherwise disclosed to a third party for monetary or other valuable consideration any Personal Information subject to the CCPA.
Your Rights Under the CCPA
As a California resident, you have the right to request that we disclose certain information about our collection and use of your personal information over the past twelve (12) months including:
The categories of Personal Information we have collected about you;
The categories of sources from which we have collected Personal Information about you;
The business or commercial purpose for collecting that Personal Information;
The business purpose for disclosing that Personal Information to third parties;
The categories of third parties with whom we have shared or share that Personal Information;
The categories of Personal Information we have disclosed or shared with a third party for a business purpose; and
The specific pieces of Personal Information we have collected about you.
Deletion Request Rights
California law gives you the right to request the deletion of your Personal Information. We limit the Personal Information that we collect from you and only collect Personal Information from you for business or commercial purposes. Splitero is providing the following methods to request deletion to comply with the CCPA. However, please keep in mind that Splitero is not required to honor your request for deletion if the Personal Information is needed for a business purpose.
Exercising your Rights
If you are a California resident, you can submit a request to us by:
Only you, or a person registered with the California Secretary of State whom you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
You may only make a verifiable consumer request twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the California resident about whom we collected personal information or an authorized representative of such a resident.
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. Our practices with regard to verifying a request will vary depending on the request and the information we have on the person making the request.
Response Time and Method
We will respond to your verifiable request within ten (10) days of receipt. We will provide access to personal information within forty-five (45) days of receiving your request. If we require more time (up to 90 days), we will notify you in writing and inform you of the reason. We will deliver our written response by mail or electronically (provided we can do so securely) at your direction. The response we provide will also explain the reasons we cannot comply with a request, if applicable. Further, we will not provide Personal Information, such as a Social Security number or any other specific pieces of Personal Information, if the disclosure could result in unauthorized access, causing fraud or other security risks. We will only use the personal information you provide to verify your identity or identity of the individual on whose behalf you are making the request.
You have the right to not receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
Information for Parents or Guardians
We do not knowingly collect or maintain information about children under the age of 16 unless that information is provided by a parent, legal guardian, or authorized adult.
Changes to this Privacy Notice
We reserve the right to update this Privacy Notice at any time to reflect changes in our business, legal or regulatory obligations. Any changes will be immediately effective upon the posting of the updated Privacy Notice.
If you have any questions or concerns regarding our Policy, please send us a detailed message to [email protected], and we will try to resolve your concerns
8910 University Center Lane, Suite 400
San Diego, CA 92122