My AccountPrivacy Policy for California Residents
Last modified: July 12,2023
This Privacy Notice for California Residents (“Notice”) applies specifically to California residents covered under the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act 2020 (“CPRA”), collectively referred to in this notice as the “CCPA”. This notice is provided by Skopos Financial, LLC d/b/a Reprise Financial (“Reprise Financial”).
Applicability
This notice explains how Reprise Financial collects, uses, and discloses personal information about California residents that is subject to the CCPA. Under the CCPA, “Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.
The definition of Personal Information under the CCPA does not include:
- Publicly available information made lawfully available from public records
- Deidentified or aggregated consumer information
- Personal Information covered by specific federal and state privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”), the California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1999 (“DPPA”).
Reprise Financial only collects information reasonably linked with a particular California consumer or household that is subject to one of these exceptions. As a result, no information that we collect about California residents, including those who apply for or obtain financial products or services offered through Reprise’s website, is subject to the CCPA.
For more information about how we collect, disclose, and secure information not covered by the CCPA, please review Reprise Financial’s Online Privacy Policy and Privacy Notice
Notice of Collection of Consumer Information
As noted above, none of the information Reprise Financial collects is Personal Information as defined by the CCPA. However, Reprise Financial does collect information on consumers. In the interest of transparency about our privacy practices, we providing you with the below disclosures concerning how we collect, use, and disclose consumer information and your rights generally under the CCPA. We collect consumer information about California residents depending on the type of interaction and relationship you have with us. For example, we collect personal information about California residents who:
- Visit and/or use our website
- We market to for our financial products and services
- Communicate with us regarding their application or financial product with Reprise Financial
In particular, we have collected the following categories of consumer information from California residents within the last twelve (12) months:
| Categories of Consumer Information | Examples | Collected |
|---|---|---|
| A. Identifiers. | Name, postal address, Internet Protocol address, email address, account name, Social Security number, driver’s license number, state identification card number, passport number, or other similar identifiers. | Yes |
| B. Categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)). | 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, employment, employment history, bank account number, credit card number, or debit card number. Some personal information included in this category may overlap with other categories. | Yes |
| C. Protected classification characteristics under California or federal law. | Age, veteran or military status. | Yes |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Yes |
| E. Biometric information. | Keystroke information. | Yes |
| F. Internet or other similar network activity. | Browsing history, or information on a consumer’s interaction with a website, application, or advertisement. | Yes |
| G. Geolocation Data. | Internet Protocol address | Yes |
| H. Sensory Data. | Audio or visual information. | Yes |
| I. Professional or employment-related information | Current or past employment information. | Yes |
| J. Sensitive Personal information | Social Security number, driver’s license, number state identification card number, passport number, bank account number, credit card number, debit card number, and Internet Protocol address. | Yes |
Sources of Consumer Information
In the last 12 months, we obtained the categories of personal information listed above from the following categories of sources:
- Directly from California residents. For example, when you provide information on forms completed on our website (www.reprisefinancial.com).
- Indirectly from California residents. For example, from observing your actions on our website (www.reprisefinancial.com).
- Consumer reporting agencies. For example, we obtain information included on your credit report when you apply for a loan with us.
- Data Brokers. For example, we obtain information from data brokers, including consumer reporting agencies, to identify marketing prospects and to deliver marketing communications.
- Public record sources. For example, we may verify your vehicle information by using available public record sources.
- Service providers. For example, we use fraud detection tools to verify your identity when you apply for a loan with us. We also use service providers to securely link to your bank account to verify your information during the loan application process.
Disclosure of Consumer Information
We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.
We do not sell or share personal information as defined under the CCPA. As described in Reprise’s Online Privacy Policy, we do not collect personal information of consumers under 16 years of age.
In the preceding twelve (12) months, Reprise Financial has disclosed the following personal information categories to the categories of third parties indicated in the chart below.
| Consumer Information Category | Category of Third-Party Recipients | ||
|---|---|---|---|
| Business Purpose Disclosures | Sales | Sharing | |
| A: Identifiers. | Service Providers Government entities | None | None |
| B: California Customer Records personal information categories. | Service Providers Government entities | None | None |
| C: Protected classification characteristics under California or federal law. | Service Providers | None | None |
| D: Biometric information. | Service Providers | None | None |
| E: Internet or other similar network activity. | Service Providers | None | None |
| F: Geolocation Data | Service Providers | None | None |
| G: Sensory Data | Service Providers | None | None |
| H: Professional or employment-related information. | Service Providers | None | None |
| I: Sensitive Personal Information | Service Providers Government entities | None | None |
Data Retention
We will retain your information only for as long as necessary for the purposes for which the information was collected (e.g., while your loan is open) and to the extent required to comply with applicable federal and state laws, statutes, regulations, or for legal or other obligations.
The Business Purposes for Which We Collect or Disclose Your Personal Information
The purposes for which we use the personal information we collect depends on our relationship and the context of the interaction with the specific California resident. We may collect personal or disclose personal information:
- To respond to requests we may receive from your in the processing of your loan application or in the servicing of your loan, such as processing payments or retrieving transactional information from your bank.
- To detect and prevent fraud.
- To operate and maintain our business.
- To verify the quality of our services, in addition to verifying enhancements to services we perform and manage.
- To communicate with you via phone calls, pre-recorded messages, text message, email and physical mail.
- To ensure the security and integrity of our products and services, including our website and other assets.
- As required to comply with applicable laws and regulations, including responses to law enforcement requests.
- To report account status and payment history information to national credit reporting agencies (NCRAs)
- As otherwise set forth in applicable law.
Disclosure of Sensitive Consumer Information
We may share your sensitive personal information by disclosing it to a third party for one of the business purposes disclosed in the section above. We will not use or disclose your sensitive personal information for purposes that require a notice under applicable law.
Requests Under the CCPA
If you are a California resident, you have the right to request the following concerning Personal Information:
- The categories of personal information that we collected about you.
- The categories of sources from which the personal information was collected.
- The business purpose for collecting personal information.
- The specific pieces of personal information that we collected about you.
- The categories or personal information we disclosed for a business purpose, and for each identified category, the categories of third parties with whom we shared that specific category of personal information.
- To correct inaccurate personal information that we maintain about you.
- To delete the personal information we collected about you.
The CCPA provides California residents with the right to stop businesses from selling and sharing their personal information. Reprise Financial does not provide this option as we do not sell or share personal information as defined by the CCPA.
The CCPA also provides California residents with the right to stop businesses from using or disclosing their sensitive personal information. Reprise Financial does not provide this option as we use and disclose sensitive personal information. You also have the right to not receive discriminatory treatment for exercising your rights under the CCPA.
As noted above, none of the information Reprise Financial collects is subject to the CCPA and these rights.
How to Submit a Request
If you are a California resident, you may submit a request by using our self-service California Privacy Request Form, or by calling us at 877-437-0089 (Monday/Tuesday/Thursday Friday 6am PST – 2pm PST). To submit a request, we require identifying information, including your name, address, date of birth, and social security number, for verification against the information in our systems.
As the consumer information we collect is not subject to the CCPA, if you submit a CCPA
request, we may not honor your request.
Submitting Requests on Another’s Behalf
You may make a request on behalf of a California resident if you are authorized to do so. We must be in receipt of appropriate documentation, including a power of attorney or signed authorization form, confirming that you have the authority to act on behalf of the individual for whom you are submitting the request. As part of our verification process, we may also contact the individual to confirm that they provided this authorization to you and to confirm how they want to receive a response.
To submit a request on behalf of a California resident, you may use either of the methods listed under “How to Submit a Request” above.
Contact Information
You may contact us via email about this Privacy Notice for California Residents or our CCPA practices. Our email address is [email protected].
Changes and Modifications
Reprise Financial may change or update this Notice. When we do, we will post the updated Notice on this page with a new “Last Updated” date. Changes to this Notice will become effective when posted unless indicated otherwise.
