Camino Financial, Inc.
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 these California Disclosures and Privacy Policy:

1. Personal Information We Collect

1. What personal information does not include

2. How we obtain your personal information

3. Consent during application process

4. How we may use your personal information

5. How we may share your personal information

6. Your personal information in the last 12 months

7. Sale of personal information

2. Your rights under the California Consumer Privacy Act of 2018

1. Your right to request what information has been collected and how it has been used (“Right to Know”)

2. Your right to request deletion of your personal information (“Right to Delete”)

3. Right to opt-out of the sale of your personal information (“Right to Opt-Out”) and submitting a Request to Opt-Out

4. Right to not be discriminated against for exercising your rights under the California Consumer Privacy Act (“Right to Non-Discrimination”)

3. Submitting a Request to Know or Request to Delete

1. How to submit a request

2. Authorized agents

3. Response timing and delivery method

4. Security

5. Telephone and email communications

6. Do Not Track signals

7. Changes to the California Disclosures and Privacy Policy

8. How to contact us

Below is the legal information we are required to share:

These California Disclosures and Privacy Policy supplement the information contained in the Privacy Policy of www.caminofinancial.com and Camino Financial, Inc. (collectively, “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 privacy laws. Any terms defined in the CCPA have the same meaning when used in this policy.

1. Personal Information We Collect and Share

We collect information that identifies, relates to, describes, references, is 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

• Publicly available information from government records

• De-identified or aggregated consumer information

• Information excluded from the CCPA, like:

  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

  • 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 That 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;

• “Geolocation Data” such as physical location or movements;

• “Sensory Data” such as audio, electronic, or visual information;

• “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

Directly from you or during our verification process of your application.

• You enter or provide us with information online, by email, by phone, or by document upload. For example, when you apply for a loan, show us your government issued ID, or pay your bill.

• We will also collect information required to verify your personal and/or business information to qualify you for loans directly funded by Camino Financial, or with active banks, non-depository lenders, and other lending sources (“Recipient Lenders”). For example, we collect information that includes, but is not limited to, your financial statements, bank statements, personal and business information, personal and business credit history, social security number, tax ID number and bank information. We may visit your website, public disclosures and social media outlets to obtain more information.

Directly and indirectly from you based on activity on our website.

• For example, from submissions through our website or website usage details collected automatically.

• For example, from companies that work with us to market our products to you, Recipient Lenders, and brokers in connection with providing the financial product(s) you request.

From service providers and third-parties that interact with us in connection with the services we perform.

• You give consent for Camino Financial and Recipient Lenders to request credit report(s) on all persons described in the Terms of Use from one or more consumer and business reporting agencies, such as TransUnion, Experian and Equifax, and from other credit bureaus, banks, creditors and other third parties.

• From other brokers, service providers, and third parties that provide data we use in underwriting or in protecting you and our products from fraud and identity theft.

1.4 Consent for During Application Process:

As part of the application process, you authorize Camino Financial employees or representatives to complete the fields required within our loan application on your behalf, subject to your review. You also consent to the release, by any creditor, financial institution, or other person or entity who has done business with you of information relating to any of you, excluding information directly or indirectly taken from personal or business credit reports, to Camino Financial and to each of the Recipient Lenders, on its own behalf. Once you have submitted an application, we may reach out to you again for more information.

1.5 How We Use Your Personal Information

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

1. Performing services such as 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:

   • To fulfill or meet the reason for which the information is provided.

   • To provide you with information, products, or services that you request from us.

   • 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.

   • 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. Undertaking internal research for technological development and demonstration.

3. Debugging to identify and repair errors that impair existing intended functionality.

4. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

5. Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

6. Short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

7. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

8. To communicate with and engage new customers.

9. To comply with the law and participate in legal proceedings.

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

1.6 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. Examples of who we share with include:

• Service providers.

• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. Third parties include our marketing partners, Recipient Lenders, credit reporting agencies, advisors such as lawyers, bankers, and insurers where necessary in the course of the professional services that they render to us, and regulators / auditors:

• With marketing partners we share Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Geolocation Data, and Professional or Employment Related Information;

• With Recipient Lenders we share Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Geolocation Data, Sensory Data, and Professional or Employment Related Information;

• With credit reporting agencies we share Identifiers, Other Personal Information, Commercial Information, Protected Characteristics, and Professional or Employment Related Information;

• With advisors we share Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Geolocation Data, Sensory Data, and Professional or Employment Related Information; and

• With regulator / auditors we share Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Geolocation Data, Sensory Data, and Professional or Employment Related Information.

1.7 Sale of Personal Information

You have the right to opt-out of the “sale” of your personal information. Under the CCPA, “sale” is defined broadly is not limited to just the payment of money. We do not directly sell your personal information in the conventional sense (i.e., for money). Like many companies, we use services to help us deliver interest-based ads to you. Sometimes the sharing of personal information with third party companies for marketing can qualify as a “sale.”

We share Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity,
Geolocation Data, and Professional or Employment Related Information with companies that work with us to market our products to you.

We do know knowingly “sell” the personal information for California residents under the age of 16.

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 either:

• 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 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 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.

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 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 Right to Opt-Out and Submitting an Opt-Out Request

You have the right to opt-out of the “sale” of your personal information.
You can exercise your right to opt-out by either:
Calling us at: (800) 852-0655
Emailing us at: DoNotSellMyInfo@caminofinancial.com

A Request to Opt-Out must:

• Provide your name, email address, and telephone number.

• State that you want to opt-out of the sale of your personal information.

Before we can respond to a Request to Opt-Out 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 DoNotSellMyInfo@caminofinancial.com and provide the following information:

1. To verify your authorization 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 filing showing authorization,

   • written permission from the California resident,

   • or power of attorney

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.
     

We will process your Request to Opt-Out within 15 business days and will honor your request for 12 months. We will instruct receiving third parties to delete your personal information as well.

2.4 Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. 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: (800) 852-0655

Emailing us at: privacy@caminofinancial.com
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 collected 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, phone number, etc.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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 privacy@caminofinancial.com and provide the following information:

1. To verify your authorization 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 filing showing authorization,

   • written permission from the California resident, or

   • power of attorney

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. 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 of its receipt. 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 response in a portable and, to the extent technically feasible, in a readily useable 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. Security

We take the security of your information very seriously. We protect your information with 2048 bit Secure Sockets Layer (SSL) encryption. This creates a bank level encrypted connection when submitting application forms on the Camino Financial website. All data is securely kept on Amazon Web Service’s servers in the United States.

If you allow Camino Financial to see your banking information online rather than in paper form, we may record that information on a read-only basis. We do not have access to change, edit, or modify your online banking account information in any way, nor to make any transactions on your behalf.

5. Telephone and email communications

If you provide us with your telephone number, then as set forth here and in our Terms of Service, we may call or text with alerts and summaries of your account activity. If you provide us with your email address, we may send alerts, summaries of your account activity, newsletters, and from time to time, emails promoting Camino Financial or goods or services for other entities. If you agree and voluntarily provide us with your telephone number, we may call you promoting Camino Financial or goods or services for other entities.

You may opt-out of receiving our newsletters, promotional emails, or promotional calls by (1) clicking unsubscribe in promotional emails and/or newsletters; (2) sending us an e-mail at info@caminofinancial.com asking to opt-out of promotional calls and/or promotional emails; or (3) calling us at (800) 852-0655 to opt-out of receiving promotional calls and/or promotional emails. To opt-out, you must provide us with your name and telephone number and/or email address (as applicable). Opting-out of promotional calls or promotional emails will not end transmission of service-related telephone calls and emails.

6. Do Not Track signals

Our site will respond to Do Not Track Signals and user-enabled global privacy settings an opt-out of the sale of personal information. Such a request will be process as discussed above in Section 2.3.

7. Changes to the California Disclosures and Privacy Policy

We reserve the right, at our sole discretion, to make changes to the California Disclosures and Privacy Policy from time to time. If we do so, we will provide notifications to that effect as required by applicable law. However, we are not required to provide you with notice of all changes; therefore, you should review the California Disclosures and Privacy Policy frequently. Consistent with our Terms of Use and applicable law, you agree to accept revised versions of the California Disclosures and Privacy Policy on www.caminofinancial.com and agree postings constitute notice to you of the revised version of the California Disclosures and Privacy Policy.

8. 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:

Privacy Support Phone: (800) 852-0655
Privacy Support E-Mail: privacy@caminofinancial.com
Website: www.caminofinancial.com
Postal Address: Camino Financial, Inc.
Attn: Privacy Team309 E. 8th Street, Suite 601
Los Angeles, CA 90014