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:
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:
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:
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:
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
