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California Privacy Notice (CCPA/CPRA)
Last Updated: 25 August 2025
This notice supplements the Refi LLC Privacy Policy and applies to California residents (and, where noted, residents of states with substantially similar privacy laws). It explains your rights and how to exercise them—including your right to opt out of the sale or sharing of personal information by using our “Do Not Sell or Share My Personal Information” controls. We also honor Global Privacy Control (GPC) or other state‑approved universal opt‑out signals.
At‑a‑Glance: Your Rights
● Know / Access what data we hold and how we use it
● Delete your data we collected from you
● Correct inaccurate data
● Opt‑Out of Sale or Sharing of personal information (including cross‑context behavioral advertising)
● Limit Use of Sensitive Personal Information to “necessary and proportionate” purposes
● Portability of your data
● Opt‑Out of significant Automated Decision‑Making (when final rules are effective)
● Non‑Discrimination for exercising your rights
We honor GPC signals as valid opt‑out and sensitive‑data‑limit requests. We do not knowingly sell or share personal information of individuals under 16 without opt‑in consent.
1) Scope & Key Definitions
This notice applies to data practices that may constitute a “sale” (exchange for monetary/other valuable consideration) or “sharing” (disclosure for cross‑context behavioral advertising) under the CCPA/CPRA and similar state laws. Examples can include disclosing identifiers (e.g., IP address, hashed email) and Internet or network activity to advertising/analytics partners to measure performance or show relevant ads on our sites or elsewhere.
Sensitive personal information may include precise geolocation, account log‑in credentials, financial data, or government IDs; we restrict use to “necessary and proportionate” purposes (e.g., security, fraud prevention, authentication).
2) Categories Collected/Disclosed (Past 12 Months)
We may collect and disclose the following categories and, where indicated, sell/share them for the purposes described in Section 3: Identifiers; Customer Records; Protected Classification Traits; Commercial Information; Internet/Network Activity; Geolocation; Audio/Visual Recordings; Sensitive PI; Inferences. See table and details in our master (with “Sold/Shared” marked where applicable).
Note on click traffic and partner landing pages: When you click an outbound link or we route paid click traffic to a partner destination, you will be subject to that partner’s site and privacy practices. We do not control third‑party websites and are not responsible for their content or independent data practices. Please review their privacy notices directly. Where feasible, we pass applicable opt‑out preferences to downstream partners and notify service providers/contractors of sale/share opt‑outs within 15 business days so they can honor your choice.
3) Why We Use Information
We use personal information to provide and improve services, prevent fraud/security incidents, deliver/measure advertising and marketing, process transactions and support, perform analytics/research, and comply with law. Sensitive PI is used only for “necessary and proportionate” purposes (e.g., authentication, fraud prevention).
4) Your Privacy Choices (with timelines)
A. Do Not Sell or Share My Personal Information
Use any of these methods:
- Email: [email protected] (subject: “Do Not Sell or Share”)
- Universal Signal: Enable GPC / state‑approved UOOM in your browser—our systems honor it automatically.
We process sale/share opt‑outs within 15 business days and notify downstream providers in the same window.
B. Limit Use of Sensitive PI
Submit via the same methods; we process within 15 business days.
C. Access / Delete / Correct / Portability
Submit via webform, email, or phone; we confirm receipt within 10 business days and fulfill within 45 days (one 45‑day extension if needed).
D. Marketing Communications (TCPA & CAN‑SPAM context)
● Calls/Text Messages: Reply “STOP” to any SMS, or use the webform/email/phone above to revoke consent or add your number to our internal DNC. We complete within 10 business days (Florida texts within 15 days). We also scrub numbers against federal, state, and internal Do‑Not‑Call lists before dialing and maintain time‑stamped logs of consent/revocation.
● Email Marketing: Use the Unsubscribe link or contact us; we honor requests within 10 business days.
Important: A sale/share opt‑out controls cross‑context ads and data disclosures; it does not by itself stop calls/texts/emails you previously consented to. Manage calls/texts/emails using the methods above.
5) How to Submit Requests (including Authorized Agents)
You (or your authorized agent) may submit requests via the channels above. We verify requests by matching the information you provide (e.g., name, email, phone, recent interactions) with our records. Authorized agents must provide written authorization or a power of attorney and may need to verify their own identity; in some cases, we may ask you to confirm the request directly.
6) Additional Ad‑Choice & Cookie Controls
You can further limit third‑party tracking by using the DAA and NAI opt‑out tools and DAA AppChoices mobile app. (You will still see ads; they just won’t be based on sale/sharing.) Manage cookies in our Cookie Preferences Center (link in footer). GPC is honored to the extent required by law.
7) Minors
We do not knowingly sell or share personal information about individuals under 16 without affirmative opt‑in consent. Parents/guardians may request deletion via the channels above.
8) Verification, Timelines & Non‑Discrimination
We acknowledge requests within 10 business days and respond within 45 days (with one possible 45‑day extension and explanation). We will not discriminate against you for exercising your rights (subject to lawful loyalty/financial‑incentive programs we describe separately).
9) Financial Incentives & Loyalty Programs
If offered (e.g., coupons for newsletter sign‑ups), we will disclose the material terms, categories of PI involved, and our good‑faith value calculation. Participation is voluntary and may be withdrawn at any time.
10) Data Retention
We retain personal information only as long as necessary for the purposes described or as required by law. Typical retention periods (e.g., consent logs 5 years; analytics 18 months; call recordings 2 years) are set in our Privacy Policy/Data Retention Schedule.
11) Audio/Call Recording Disclosure
Inbound and outbound calls may be recorded or monitored for quality, training, and compliance. If you do not consent, please discontinue the call and use alternate channels.
12) Third‑Party Links, Partners, and Click‑Through Traffic
Our sites may include links to third‑party sites, or we may route paid click traffic to partner landing pages. Those sites are not controlled by Refi LLC. We provide links for convenience and assume no responsibility for third‑party content or practices. Review each partner’s privacy notice and exercise rights with them directly for their independent processing.
Partners who purchase or receive traffic/data from us must comply with applicable law (including TCPA/mini‑TCPA, CAN‑SPAM, CCPA/CPRA, DNC rules), maintain and honor valid consent, and indemnify us for non‑compliance per our Terms.
13) California “Shine the Light”
Once per calendar year, you may request a list of third parties to whom we disclosed personal information for their direct‑marketing purposes. Send a written request to: Attention: Privacy / Shine the Light, Refi LLC, 2637 E Atlantic Blvd, Pompano Beach, FL 33062.
14) California Delete Act (SB 362) Notice
Starting January 1, 2026, California residents may use the CPPA’s DELETE/DROP platform to request deletion of data held by data brokers. We will treat valid DROP submissions as CCPA/CPRA deletion requests.
15) Accessibility & Alternate Formats
If you need this Notice in an alternate format (e.g., large print, Braille, audio), contact [email protected].
16) Updates to This Notice
We may revise this Notice periodically. Material changes will be posted here at least 30 days before taking effect, and the “Last updated” date will reflect the current version.
17) Contact Us
● Email: [email protected]
● Mail: 2637 E Atlantic Blvd, Pompano Beach, FL 33062
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