California Consumer Policy

Smart Lending – California Consumer Privacy Policy

Effective Date: August 2025
Last Updated: August 2025

This California Consumer Privacy Policy (“Policy”) supplements the [Smart Lending Privacy Policy url] and applies solely to residents of the State of California (“consumers” or “you”). We adopt this Policy to comply with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). Any terms defined in the CCPA/CPRA have the same meaning when used in this Policy.

1. Categories of Personal Information We Collect

In the preceding 12 months, Smart Lending has collected the following categories of personal information:

Category

Examples

Collected

A. Identifiers

Name, alias, postal address, email address, telephone number, IP address, account name, Social Security number, driver’s license number, passport number.

YES

B. Personal Information under Cal. Civ. Code § 1798.80(e)

Name, signature, Social Security number, physical characteristics, address, telephone number, passport number, driver’s license or state ID number, insurance policy number, education, employment, bank account number, credit/debit card number, or other financial information.

YES

C. Protected Classification Characteristics

Age, marital status, gender, veteran or military status.

YES

D. Commercial Information

Records of personal property, products or services purchased, obtained, or considered.

YES

E. Biometric Information

Fingerprints, faceprints, voiceprints (if collected through identity verification).

MAY COLLECT for verification

F. Internet or Other Electronic Network Activity

Browsing history, search history, website interaction data.

YES

G. Geolocation Data

Approximate location from IP address.

YES

H. Audio/Visual Information

Call recordings, chat transcripts.

YES

I. Professional or Employment Information

Employment history, employer name, job title.

YES

J. Education Information

Non-public educational records (if voluntarily provided).

NO

K. Inferences

Profiles based on preferences, characteristics, and creditworthiness.

YES

L. Sensitive Personal Information

Social Security number, driver’s license, financial account number with access codes, precise geolocation, racial or ethnic origin (if voluntarily provided), union membership.

YES

2. Sources of Personal Information

We obtain personal information from:

  • Directly from you (applications, forms, communications).
  • Credit reporting agencies (with your consent).
  • Lending partners and other financial institutions.
  • Service providers who assist us in delivering Services.
  • Automatically through cookies and website interactions.
  • Publicly available sources.

3. How We Use Personal Information

We may use or disclose your personal information for the following business purposes:

  • To fulfill the reason you provided the information.
  • To process loan applications and match you with lending partners.
  • To verify your identity and prevent fraud.
  • To comply with legal and regulatory obligations.
  • To improve our website and customer service.
  • To send relevant marketing communications (subject to your opt-out rights).

4. Disclosure of Personal Information

In the past 12 months, we have disclosed the following categories of personal information for a business purpose:

  • Identifiers
  • Personal information under Cal. Civ. Code § 1798.80(e)
  • Commercial information
  • Internet/network activity
  • Geolocation data
  • Audio/visual information
  • Professional/employment information
  • Inferences

We disclose this information to:

  • Lending partners to provide loan offers.
  • Service providers to operate and improve our Services.
  • Credit bureaus for credit reporting purposes.
  • Government and regulatory authorities as required by law.

5. Sale or Sharing of Personal Information

Smart Lending does not sell personal information as defined under CCPA/CPRA.
We may “share” personal information for the purpose of crosscontext behavioral advertising. If we do, you have the right to opt out at any time (see Section 7 below).

6. Your Rights Under CCPA/CPRA

As a California resident, you have the following rights:

  • Right to Know – You can request that we disclose:
    • Categories of personal information we collected.
    • Categories of sources of that information.
    • Our business or commercial purposes for collecting or sharing it.
    • Categories of third parties with whom we share it.
    • Specific pieces of personal information we collected about you.
  • Right to Delete – You can request that we delete your personal information, subject to certain exceptions.
  • Right to Correct – You can request that we correct inaccurate personal information.
  • Right to Opt Out of Sharing – You can request that we do not share your personal information for crosscontext behavioral advertising.
  • Right to Limit Use of Sensitive Personal Information – You can request that we limit use of sensitive information to what is necessary to provide the Services you request.
  • Right to NonDiscrimination – We will not discriminate against you for exercising your CCPA/CPRA rights.

7. How to Exercise Your Rights

You can exercise your CCPA/CPRA rights by:

  • Phone: 866-214-0004
  • Email: privacy@smartlending.com
  • Online Form: [URL to Opt Out Notice]

We will verify your identity before fulfilling your request. You may authorize an agent to act on your behalf by providing written permission.

8. Do Not Sell or Share My Personal Information

You have the right to opt out of the “sale” or “sharing” of your personal information for crosscontext behavioral advertising. To exercise this right:

  • Call: 866-214-0004
  • Email: privacy@smartlending.com

9. Retention of Personal Information

We retain personal information for as long as necessary to:

  • Provide Services.
  • Comply with legal obligations.
  • Resolve disputes.
  • Enforce our agreements.

10. Changes to This Policy

We may update this Policy periodically. When we do, we will update the “Last Updated” date and post the revised Policy on our website.

11. Contact Information

Smart Lending Corporation
1111 6th Ave STE 300, San Diego, CA 92101

Email: privacy@smartlending.com
Phone: 866-214-0004