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We use cookies and similar technologies on our websites and mobile applications
to ensure you get the best experience on our website. California consumers:
Please see the Notice at Collection contained in our California Privacy
Statement for a description of the personal information Ascentium collects and
how Ascentium may use and disclose information we collect. By continuing to
browse our websites and apps, you accept the use of cookies. Learn more.
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CALIFORNIA PRIVACY STATEMENT
This California Privacy Statement is for California Residents only and
supplements Ascentium Capital’s Privacy and Security Notice.
This policy:
* Describes the personal information that Ascentium Capital, a division of
Regions Bank, (“we,” “our,” or “us”) collects in the course of its business,
* Explains how this information is collected, used, shared, and disclosed,
* Describes rights provided by the California Consumer Privacy Act of 2018, as
amended by the California Privacy Rights Act (the “CCPA”) to California
Residents (“consumers” or “you”) regarding their personal information, and
* Explains how consumers can exercise those rights.
With a limited exception, and as noted in other sections of this policy, certain
provisions of the CCPA do not apply to:
* Certain personal information covered by or collected under industry-specific
privacy laws including, but not limited to, the Health Insurance Portability
and Accountability Act of 1996, the California Confidentiality of Medical
Information Act, the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act,
the California Financial Information Privacy Act, and the Driver's Privacy
Protection Act of 1994.
WHAT IS PERSONAL INFORMATION 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 you (“personal information”). “Personal
information” does not include: (1) publicly available information, such as
information that is lawfully made available from federal, state, or local
records, and (2) de-identified or aggregate consumer information.
PERSONAL INFORMATION WE COLLECT, USE OR SHARE
In connection with our business activities, we may collect, use, or share your
personal information.
Collection of Personal Information
The following are the categories of personal information under the CCPA that we
have collected on consumers in the preceding 12 months:
* Identifiers. This may include 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.
* Personal information described in the California Customer Records Statute
(Cal. Civ. Code § 1798.80(e)). This may include 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.
* Characteristics of Protected Classification under California or Federal Law.
This may include age, 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).
* Commercial information. This may include Records of personal property,
products or services purchased, obtained, or considered, or other purchasing
or consuming histories or tendencies.
* Internet or other similar network activity. This may include browsing
history, search history, or information on a consumer's interaction with a
website, application, or advertisement.
* Geolocation data. This may include physical location or movements.
* Professional or employment-related information. This may include current or
past job history or performance evaluations.
* Non-public education information (per the Family Educational Rights and
Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)). This may include
education records directly related to a student maintained by an educational
institution or party acting on its behalf, such as report cards, transcripts,
class lists, student schedules, student identification codes, student
financial information, and student disciplinary records.
* Inferences drawn from other personal information. To create a profile about,
for example, an individual's preferences and characteristics.
* Sensitive personal information. This may include a social security number,
driver's license, state identification card or passport number. This term, as
used in this California Privacy Statement, also refers to geolocation data
and characteristics of protected classifications under California or federal
law.
We collect personal information for the Internal Uses and the Disclosure
Purposes described in “Use of Personal Information” and “Disclosure of Personal
Information” below. We may collect your personal information from the following
sources (“Sources”).
* You.
* Credit Reporting Agencies and Other Data and Analytics Providers.
* Unaffiliated Service Providers.
* Vendors and Equipment Suppliers.
* Unaffiliated Referral and Sales Relationships.
* Online Tools and Applications.
* Our Affiliates.
Use of Personal Information
It is our goal to provide our customers and potential customers with customized
financing options for their specific business needs, fast credit decisioning and
a simplified documentation process. After the initial transaction, our goal is
to provide customer-centric service, offer new or enhanced finance products. We
use personal information we collect for a number of different business and
commercial purposes (“Internal Uses”) in order to achieve this goal, including:
* To fulfill or meet the reason for which the personal Information was provided
and to provide you with information, products or services that you may
request from us. For example, when you inquire about, or seek your, business
financing from us, we use personal information to provide you with
information, products and services that you request from us. In addition, we
use personal information to determine your business’ eligibility for such
financing and the terms and conditions thereof.
* To perform services for you or in connection with your transaction and to
improve the quality of those services. For example, if we have approved your
business financing, we use personal information to complete the financing
transaction, including preparation of the financing documents, due diligence
matters to prevent fraud, confirmation of required insurance, and payment
information. In addition, we use personal information to provide ongoing
customer service, on our behalf and on behalf of others, including billing
and collection, matters relating to taxes and insurance, location of the
property financed and, if necessary, enforcement of the contract.
* For marketing purposes other than cross contextual behavioral advertising. We
use personal information to develop, promote and provide a comprehensive line
of finance products to customers and potential customers, to extend
personalized and customized messaging, quality content, and finance offers
tailored to the specific needs of businesses, as well as to enhance our
product and service offering to meet the changing needs of our customers,
potential customers, and the industries which they and we operate. Please see
below for information on how Ascentium does conduct cross contextual
behavioral advertising.
* To improve online and system functionality. We are constantly evaluating ways
to improve our user's experience, and may use your personal information to
improve the functionality and utility of our websites, mobile applications,
and social media sites, for purposes of internal research for technological
development and demonstration, to assist us in debugging to maintain and
identify and repair errors in our systems, and to audit current interactions
with you and concurrent transactions. We also use personal information to
audit and improve the security of our websites and mobile applications,
including helping to ensure security and integrity where the personal
information is reasonably necessary and proportionate for these purposes.
* To comply with laws and regulations.
* To otherwise advance our commercial or economic interest not otherwise
identified above.
Disclosure of Personal Information
We may disclose personal information for the same business and commercial
purposes as our Internal Uses of such information (“Disclosure Purposes”). We
may disclose such information to the following categories of third parties and
service providers (“Third Parties/Service Providers”) for those Disclosure
Purposes, including:
* Our Unaffiliated Service Providers: We use unaffiliated service providers to
assist us in performing a number of different functions relating to the
business and commercial purposes described in “Use of Personal Information”
above. In the course of our dealings with these service providers, we may
disclose your personal information that we have collected, including
providing personal information to service providers who assist us with
marketing our products and services to you via online advertising methods.
* Vendors and Equipment Suppliers: In connection with processing your request
for business financing, processing that transaction, and administering that
transaction following closing, we may disclose your personal information to
the business supplying the assets which you are financing or leasing in order
to confirm the assets being financed, prevent fraud, complete the document
package for the financing, and provide customer service and other information
to you or the vendor or equipment supplier. We may also disclose your
personal information to vendors and equipment suppliers to enable them to
market our products and services to you.
* Our Affiliates: We use affiliated companies to enhance our ability to provide
financing to businesses, as well as to hold, service, and administer those
financings once in place. We may also disclose your personal information to
our affiliates to enable those affiliates to market their products and
services to you, as well as to enable those affiliates to comply with their
respective obligations under state and federal rules, laws and regulations
(“Applicable Laws”).
* Governmental Authorities: We and/or our affiliates may be requested or
required to provide personal information to state or federal governmental
agencies or by a court or other judicial or legislative body (“Governmental
Authorities”). We and/or our affiliates may also disclose personal
information to courts and other judicial bodies as necessary to enforce our
rights and remedies under our financing contracts.
* A third party assuming control of us if the personal information is part of a
merger, acquisition, bankruptcy or other transaction.
* Other third parties in order to advance our commercial or economic interests
not otherwise identified above. For example, we may disclose personal
information to our third-party referral and purchaser relationships, as well
as parties who provide us with financing, their respective service providers,
and other participants in those transactions.
For each of the categories of personal information we have collected about
consumers in the preceding 12 months, below are the categories of third parties
to whom we share such personal information:
Categories of Personal Information we Collect (for a description of the types of
personal information included in these categories, see “What is Personal
Information Under the CCPA” above)
The Categories of Third Parties With Whom we Share Personal
InformationIdentifiersWe share personal information with all of the categories
of Third Parties/Service Providers.Personal information described in the
California Customer Records Statute (Cal. Civ. Code § 1798.80(e))We share
personal information with all of the categories of Third Parties/Service
Providers.Characteristics of Protected Classification under California or
Federal LawWe share personal information with all of the categories of Third
Parties/Service Providers.Commercial informationWe share personal information
with all of the categories of Third Parties/Service Providers.Internet or other
similar network activityWe share personal information with all of the categories
of Third Parties/Service Providers.Geolocation dataWe share personal information
with all of the categories of Third Parties/Service Providers.Professional or
employment-related informationSee our CCPA Job Applicant Disclosure and CCPA
Employee Disclosure.Non-public education information (per the Family Educational
Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99))See our CCPA Job
Applicant Disclosure and CCPA Employee Disclosure.Sensitive Personal
InformationWe share personal information with all of the categories of Third
Parties/Service Providers.Inferences drawn from other personal informationWe
share personal information with all of the categories of Third Parties/Service
Providers.
Sharing Your Personal Information for Cross-Contextual Behavioral Advertising
Purposes
We may share your personal information with service providers and third parties
for cross-contextual behavioral advertising.
In the preceding 12 months, we have shared the following categories of consumer
personal information for cross-contextual behavioral advertising to service
providers and the following categories of third parties:
* Identifiers to Social Media Company.
* Personal information described in the California Customer Records Statute
(Cal. Civ. Code § 1798.80(e)) to Social Media Company.
* Internet or other similar network activity to Social Media Company.
* Geolocation data to Social Media Company.
* Inferences drawn from other personal information to Social Media Company.
* Sensitive personal information to Social Media Company.
We may share your personal information for the following purposes:
* Advertising or Marketing Services: We share personal information to provide
advertising or marketing services on our own behalf.
* Commercial/Economic Interests: We share personal information to advance our
own commercial or economic interest.
In the preceding 12 months, we have not sold any personal information. In
addition, we do not sell personal information. Also, it is our business practice
not to sell personal information of minors under 16 years of age and we have no
actual knowledge of doing so.
We also have not used or disclosed Sensitive Personal Information outside of the
exceptions allowed for in the CCPA and its implementing regulations.
How Long We Retain Your Personal Information
We store personal information for as long as we believe is reasonably necessary
or appropriate to fulfill our business purposes or to comply with applicable
law, audit requirements, regulatory requests, or orders from competent courts.
YOUR RIGHTS UNDER THE CCPA
As described in more detail below, the CCPA provides you with certain rights
regarding the collection, use, retention, and disclosure of your personal
information.
The Right to Know About Personal Information Collected, Used or Disclosed
When we collect information, you have the right to know:
* The categories of personal information to be collected, the purposes for
which the categories of personal information are collected or used, and
whether that information is sold or shared;
* The categories of sensitive personal information to be collected, the
purposes for which the categories of sensitive personal information are
collected or used, and whether that information is sold or shared; and
* The length of time the business intends to retain each category of personal
information, including sensitive personal information.
You also have the right to request that we provide you with certain information
about the personal information we collect, use, or disclose about you as well as
the categories and specific pieces of information that we have collected about
you since January 1, 2022. Specifically, you have the right to request the
following information:
* The categories of personal information we have collected about you.
* The categories of sources from which we have collected personal information
about you.
* Our business or commercial purpose for collecting your personal information.
* The specific pieces of personal information we have about you.
* If we disclosed your personal information for a business or commercial
purpose:
* The categories of personal information that we disclosed about you for a
business or commercial purpose; and
* The categories of third parties to whom your personal information was
disclosed for a business or commercial purpose, and which category of
personal information was disclosed to that third party.
* If we shared your personal information, the categories of personal
information that we collected and shared about you and, for each category
identified, the categories of third parties to which we shared that
particular category of personal information.
However, there is certain information that we will not disclose to you. This
information includes, but is not limited to, your Social Security number,
driver's license number or other government-issued identification number,
financial account number, any health insurance or medical identification number,
an account password, or security questions and answer.
Submitting a Verifiable Request to Know About Personal Information Collected or
Disclosed
To exercise your Right to Know, please submit a verifiable consumer request to
us by either:
* Calling us at 833-719-0114
* Submitting the Right to Know Request Form
Only you (or an authorized agent) may make a verifiable consumer request for
your personal information.
The Right to Request Deletion of Personal Information
You have the right to request that we delete any personal information that we
have collected from you and maintained about you. Once we receive and confirm
your verifiable consumer request, if we determine that we must comply with a
deletion request and delete your personal information from our records, we will
also direct any service providers we work with to also delete your personal
information from their records.
Please note that we may deny your deletion request for a number of different
reasons, which are identified in the CCPA.
Submitting a Verifiable Request to Delete Personal Information
To exercise your Right to Request Deletion, please submit a verifiable consumer
request to us by either:
* Calling us at 833-719-0114
* Submitting the Request to Delete Personal Information Form
Only you (or an authorized agent) may make a verifiable consumer request for
your personal information.
The Right to Request Correction of Inaccurate Personal Information
You have the right to request that we correct any inaccurate personal
information that we have collected from you or and/or maintained about you. Once
we receive and confirm your verifiable consumer request, if we determine that we
must comply with a correction request and correct inaccuracies in-or, as may be
appropriate, delate-your personal information from our records, we will also
direct any service providers we work with to correct or delete your personal
information from their records. If we store any of your personal information in
our archived or back-up systems, we will correct or delete your information once
we access, restore, and/or use the systems.
Submitting a Verifiable Request to Correct Personal Information
To exercise your Right to Request Correction, please submit a verifiable
consumer request to us by either:
* Calling us at 833-719-0114
* Submitting the Request to Correct Personal Information Form
Only you (or an authorized agent) may make a verifiable consumer request for
your personal information.
The Right to Opt-Out of the Selling or Sharing of Personal Information
You have the right to opt-out of the selling or sharing of personal information
with third parties that we do business with. The exercise of this right does not
prohibit the sharing of information necessary for us to follow the law, as
permitted by law, or to give you the best service on your accounts with us.
You may opt out of the sharing of your personal information by designating your
preferences on our Do Not Share My Personal Information page.
Verifying Your Identity
We will verify your identity as follows:
* If we have provided you with business equipment financing:
* If you submit a request to know the categories of personal information, a
request to correct, or a request to delete, you will need to provide us
with (1) the agreement number of your finance or lease agreement with us
and (2) the amount of the scheduled payment under that finance or lease
agreement, which we will match with those two data points in our system to
verify your identity.
* If you submit a request to know specific pieces of personal information,
you will need to provide us with (1) the agreement number of your finance
or lease agreement with us, (2) the amount of the scheduled payment under
that finance or lease agreement, and (3) the address that is the location
of the equipment which you leased or financed through us, which we will
match with those three data points in our system to verify your identity.
You will also be required to submit a signed declaration under penalty of
perjury stating that the requestor is the consumer whose personal
information is the subject of the request.
* If we have not provided you with business equipment financing:
* If you submit a request to know the categories of personal information, a
request to correct, or a request to delete, you will need to provide us
with (1) the legal name of the business associated with your interaction
with us (for example, the legal name of the business associated with the
credit application) and (2) the legal structure of that business (for
example, "corporation," "limited liability company," "sole proprietorship,"
etc.), which we will match with those two data points in our system to
verify your identity.
* If you submit If you submit a request to know specific pieces of personal
information, you will need to provide us with (1) the legal name of the
business associated with your interaction with us (for example, the legal
name of the business associated with the credit application), (2) the legal
structure of that business (for example, "corporation," "limited liability
company," "sole proprietorship," etc.), and (3) the business address of the
business associated with your interaction with us, which we will match with
those three data points in our system to verify your identity. You will
also be required to submit a signed declaration under the penalty of
perjury stating that the requestor is the consumer whose personal
information is the subject of the request.
* There may be unusual circumstances where your interaction with us did not
yield the data points listed above. In such a case, we will separately
provide you with information on the two or three, as applicable, data points
we will use to verify you.
Our Response to Your Request to Know, Delete or Correct Personal Information
Once we receive your verifiable consumer request, we will confirm our receipt of
your request within 10 business days and provide you with additional information
about how we will process the request. Our goal is to respond to your request
within 45 calendar days of receiving the request, beginning on the day we
receive the request. However, in the event that we need more time (up to 90
calendar days) to respond to your request, we will provide you with notice and
an explanation of the reasons that we will take an additional 45 calendar days
to respond. If we are unable to comply with a given request, we will provide you
with a response explaining why we have not taken action on your request and
identifying any rights you may have to appeal the decision.
Authorized Agent for Requests
You may designate an authorized agent to make a request on your behalf. If you
would like to use an authorized agent, which is an individual or business that
you have authorized to act on your behalf, to submit a request, you must provide
the authorized agent with written permission to do so and verify your own
identity directly with us. We may deny a request from an agent that does not
submit proof that they are authorized to act on your behalf.
NON-DISCRIMINATION AND NO RETALIATION
We will not discriminate against you for exercising any of your CCPA rights. For
example, unless otherwise 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 with a different level or quality of goods or services.
* Suggest that you will receive a different price or rate for goods or services
or a different level or quality of goods or services.
CHANGE TO OUR CALIFORNIA PRIVACY STATEMENT
We are required by law to update this California Privacy Statement at least once
each year. This California Privacy Statement was last updated on 1/11/23.
CONTACT INFORMATION
If you have any questions regarding our privacy policies, our California Privacy
Statement, the ways in which we collect, use, and disclose your personal
information, or how to exercise your rights under the CCPA, please do not
hesitate to contact us at:
Phone: 833-719-0114
Email: CCPA@AscentiumCapital.com
Attn: Ascentium CCPA Team
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