California Privacy Statement

LAST REVISED: JUNE 1, 2024

This California Consumer Privacy Statement (“Statement”) supplements the FinBe USA Privacy Statement and FinBe USA Privacy Notice and applies solely to personal information we collect about California consumers, including our website visitors, job applicants and business partners, both online and offline.
Finbe, Inc. d/b/a FinBe USA and its affiliates, subsidiaries and related companies (collectively, “FinBe USA,” the “Company,” “we,” “us” or “our”) respect your privacy and are committed to protecting it through our compliance with this policy. Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.
We collect, use, and are responsible for certain personal information about you. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible as a “controller” of that personal information for the purposes of the GDPR. We are responsible for your personal information as a “business” under the CCPA/CPRA.

1. Key Terms
We, Us, Our: Finbe, Inc. d/b/a FinBe USA and its affiliates, subsidiaries and related companies
Personal Information: Any information relating to an identified or identifiable individual.
Special Category Personal Information: Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation.
Sensitive Personal Information: Personal information revealing a consumer's social security number, driver's license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer's health, sex life, or sexual orientation, contents of a consumer's mail, email and text messages where the business is not the intended recipient, genetic data, biometric information, or citizenship and immigration status.

2. Personal Information We May Collect About You
We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
Identifiers: identifiers such as 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.
Additional Data Subject to Cal. Civ. Code § 1798.80: information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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.
Account Information: account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship or immigration status, and military and veteran status.
Commercial Information: 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 Information: browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement).
Geolocation Data: vehicle location, residence, and place of employment.
Sensory Information: audio, electronic, visual, thermal, olfactory, or similar information.
Professional or Employment-Related Information: professional or employment-related information, such as resume information, occupation details, certifications and professional associations, historical compensation details, previous employment details, emergency contact information, and pre-employment screening and background check information, including criminal records information.
Education Information: high school graduation or GED attainment, colleges and universities attended, and degrees earned, information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA).
Inferences: Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

3. How Your Personal Information is Collected

We may collect your personal information from the following categories of sources:
You directly (in person, by telephone, text, email or via our website)
Third party with your consent (e.g., your bank)
Credit reporting agencies
Auto dealerships and third-party website used by dealers to generate customer leads
Collection service providers
Consumer verification service providers
Bank verification service providers
Payment processing service providers
Lien and titling vendors
Advertising networks
Internet service, software, or communications providers
Data analytics providers
Government entities
Operating systems and platforms
Social networks
Data brokers
Publicly accessible sources (e.g., property records)
Cookies on our website
Our IT and security systems

4. How and Why, We May Use Your Personal Information
Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:

To comply with our legal and regulatory obligations
For the performance of our contract with you or to take steps at your request before entering into a contract
For our legitimate interests or those of a third party
Where you have given consent

What we use your personal information for	Our reasons
To provide financing to you	For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or FinBe USA	For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, inquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g., policies covering security and internet use	For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training, and quality control	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services and those of selected third parties to: Existing and former customers Third parties who have previously expressed an interest in our services Third parties with whom we have had no previous dealings	For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers
Credit reference checks via external credit reference agencies	For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services
External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

5. Who We May Share Your Personal Information With

We may share your personal information with:
Our affiliates
Vendors who provide services on our behalf
Data analytics providers
Professional services organizations, such as auditors and law firms
Credit reporting agencies
Our insurers and brokers
Our bank[s]
Third parties approved by you, such as third-party payment providers
Other third parties we use to help us run our business, such as marketing agencies or website hosts

We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

6. Disclosure of Personal Information

In the preceding 12 months, we may have shared or disclosed the following categories of personal information for a business purpose:
Identifiers (e.g., 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)
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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 classifications under California or federal law
Commercial information (e.g., 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 information (e.g., browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, or advertisement)
Geolocation data
Audio, electronic, visual, thermal, olfactory, or similar information
Professional or employment-related information
Education information (defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA))
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
Sensitive personal information

7. How Long Your Personal Information Will Be Kept
We will keep your personal information while you have an account with us. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf
To show that we treated you fairly
To keep records required by law

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

8. Your Rights Under the CCPA/CPRA
You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know, and request disclosure of: The categories of personal information we have collected about you, including sensitive personal information The categories of sources from which the personal information is collected The categories of third parties to whom we disclose personal information, if any –and– The specific pieces of personal information we have collected about you Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information –or– Provide the personal information to you more than twice in a 12-month period
Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose	In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information. To opt-out of the sale or sharing of your personal information, complete the form on our online Privacy Notice.
Right to Limit Use of Sensitive Personal Information	You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to: Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer's current interaction with the business, provided that the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business, and As authorized by further regulations You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. To limit the use of your sensitive personal information, you may complete the form on our online Privacy Notice.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records, and Delete your personal information from our records, and Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort Please note that we may not delete your personal information if it is reasonably necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us Help to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for those purposes 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 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us Comply with an existing legal obligation Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information
Right of Correction	If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Protection Against Retaliation	You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things: Deny goods or services to you Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties Provide a different level or quality of goods or services to you Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services

9. How to Exercise Your Rights
If you would like to exercise any of your rights as described in this Privacy Policy, you can complete the form on our online Privacy Notice. You may also call us at (877) 576-2265, or email us at customerservice@finbeusa.com.

Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact us to exercise any of your rights as described in this Privacy Policy, you will need to provide us with:
Enough information to identify you (e.g., your full name, address and/or account number)
Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill), and
A description of what right you want to exercise and the information to which your request relates
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

10. Keeping Your Personal Information Secure.
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

11. Changes to This Privacy Notice
We may change this privacy notice from time to time–when we do, we will inform you via our website and/or other means of contact such as email.

12. How to Contact Us
Please contact us by any of the following methods if you have any questions about this privacy policy or the information, we hold about you.

By U.S. Mail: FinBe USA, 1475 W. Cypress Creek Road, Suite 300, Fort Lauderdale, FL 33309
By telephone: (877) 576-2265, or
By email: customerservice@finbeusa.com.

13. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to Contact Us” above).

CALIFORNIA CONSUMER PRIVACY STATEMENT

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