FlipScore
California Consumer Privacy

California Consumer Privacy Act (“CCPA”) Privacy Statement

Effective Date

01/01/2020

This California Consumer Privacy Act (CCPA) Data Processing Addendum is a direct reflection of requirements set forth by the California Consumer Privacy Act of 2018 and the amendments made in 2020. The purpose of this Statement is to help FlipScore Credit’s users understand the superseded, amended, and added regulations as per the California Civil Code §§ 1798.100 to 1798.199. This Statement also serves to notify all users clearly that FlipScore Credit is a Service Provider following the rules and regulations set forth by CCPA.

This Statement shall be applicable to collection, processing, or sale of information other than;

  • Provided by consumers to FlipScore Credit against a financial product or service,
  • Provided by consumers as a resulting of any transaction involving any FlipScore Credit product or service.
  • Obtained about consumers in connection to any financial product or service provided to said consumer.

This Addendum (“Statement”) serves as an addendum to the Terms of Service (“Agreement”) between FlipScore Credit and you (each a “Party” and collectively the “Parties”). The Statement shall remain in effect till FlipScore Credit holds on to any Personal Information (as per CCPA definition and protection) Customer shall provide or is collected as mentioned above. This Statement prevails should any conflict arise in the terms of the Agreement set forth, but doesn’t hold authority to otherwise modify it. You enter into this Statement on your own behalf and not any third party (except Authorized Affiliates), to whatever extent CCPA requires.

To get a better grip of your rights with respect to anything not mentioned in this CCPA Privacy Statement, please refer to FlipScore Credit Privacy Policies at *link*.

Notice

You are a direct representative of and warrant that you have been provided a notice that FlipScore Credit shall collect and use Personal Information consistent with Cal. Civ. Code 1798.140(t)(2)(C)(i).

Definitions

“Affiliate” represents any entity or person controlling, being controlled by, or is under common control, directly or indirectly, by you.

“Authorized Affiliate” represents any of your Affiliate(s) who are permitted to receiving benefit of Services provided by FlipScore Credit under the Agreement.

Information Collected

FlipScore Credit collects information to identify, relate, describe, reference, associate with, or could link, directly or indirectly with you or your household. This information is subject to the CCPA (“Personal Information”). Following is a breakdown of information we have collected in the past twelve (12) months, sorted with respect to categories of Personal Information:

Category Examples Collected
Identifiers Real name, address, unique personal identifier, Social Security number, online persona or identifier, IP address, email address, email account information such as name, passport number, driver's license number Yes
Personal Information listed under California Customer Records statute (Cal. Civ. Code § 1798.80(e)) Name, signature, physical description, Social Security number, mailing and permanent address, contact information, passport number, driver's license number, education, employment, insurance policy number, bank account details, credit/debit card information, medical/health insurance information. Yes
Commercial information Purchasing/consuming histories or tendencies. Yes
Biometric data Genetic data, physiological, biological, and behavioral patterns, finger, face, and voiceprints, iris/retina scans, gait, sleep, exercise, or other physical patterns No
Internet or similar network activity Internet history, website, application, or advertisement interaction Yes
Geolocation data Geolocation data Yes
Sensory data Electronic, visual, olfactory, or similar data. No
Profession-related data Job history or evaluations. Yes
Non-public educational data (as per the Family Educational Rights & Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) Educational records maintained by educational institutions, grades, transcripts, behavior, class lists, schedules, identification codes, financial information, or disciplinary records. Yes
Personal Information Inferences Inferred personal preferences, psychological trends, predispositions, attitude, intelligence level, abilities, and aptitude. Yes

Following isn't included in Personal Information:

  • Publicly available information
  • Aggregated consumer information
  • Information not covered by CCPA such as:
  • Personal Information mentioned in sector-specific privacy laws such as the Fair Credit Reporting Act (FCRA), California Financial Information Privacy Act (CalFIPA), Gramm-Leach-Bliley Act (GLBA), and Driver's Privacy Protection Act, 1994
    • Medical information constituting a clinical trial data
    • Health information covered by Health Insurance Portability and Accountability Act, (HIPAA) 1996, California Confidentiality of Medical Information Act (CMIA), or Health Information Technology for Economic and Clinical Health Act (HITECH)
    • Information gathered by FlipScore Credit from natural persons in the normal course of business, such as applying for a job
    • Information gathered from an employee, director, officer, owner, or a third-party contractor.

FlipScore Credit procures its information from a variety of sources, including but not limited to:

  • You, in both online and offline interactions with us or any service provider working under us,
  • Third parties with whom you and we deal with,
  • Any devices you use in order to get access to our services
  • Credit bureaus,
  • Marketing/analytics providers
  • Public databases,
  • Identify verification services,
  • Fraud prevention services,
  • Social media, and
  • Other source consistent with this Statement
Personal Information Usage

According to the Personal Information categories mentioned in Section 3, Table 1, FlipScore Credit may use or disclose said information for the following business purposes:

  • Fulfill the intended purpose for which said information is given to FlipScore Credit
  • Communicate with you via email alerts or call as and when business operations demand
  • Share statements concerning FlipScore Credit products or services
  • Carry out tasks, rights, and obligations arising from contracts between you and FlipScore Credit
  • To maintain information security and prosecute the same
  • Debugging, identifying, and repairing software errors in systems
  • Respond to reasonable law enforcement requests and any court orders, or state or federal regulations
  • Auditing and reporting, should there be any concern about a particular transaction and/or interaction, including but not limited to online interactions with FlipScore Credit or on our behalf
  • Improve website and application content and experience for you
  • Short-term transient use such as ad customization
  • As otherwise appropriate, necessary, or described to you upon data collection, protects rights, safety and property of FlipScore Credit or you, or as set forth in the CCPA
Sharing Personal Information

Apart from collection of Personal Information, FlipScore Credit reserves the right to disclose said information to a third party ONLY for business purposes.

FlipScore Credit has disclosed information for from the following categories for business purposes over the past twelve (12) months:

Category Details
Category A Identifiers
Category B California Customer Records Personal Information
Category F Internet or other similar network activities
Category H Sensory data
Category K Inferential data deduced from Personal Information

While keeping each of the categories mentioned in the table above, by using FlipScore Credit you agree not to object to our Personal Information usage policy. You also agree that FlipScore Credit has the right to disclose said Personal Information for business purposes as and when need be. Flip Score Credit reserves the right to disclose information to the following third parties:

  • Affiliates
  • Service providers
  • Third parties that you or other consumers may direct or allow us to disclose their personal information to.

FlipScore Credit explicitly states that it does not, and has no intention to in the future sell (as defined by the original CCPA document) any Personal Information collected in due course of the business. FlipScore Credit may share said information with express permission and/or when you make use of any FlipScore Credit products or services to intentionally interact with third parties. As the Terms of Use of FlipScore Credit suggest, FlipScore Credit shall not be held liable for misuse of said information if proper precautions have been taken by FlipScore Credit, or if the breach/misuse is a result of you sharing the information with a third party.

Furthermore, FlipScore Credit does not disclose any Personal Information of individuals who can be identified as being under the age of 16 to anyone without express affirmative authorization. This includes businesses or third parties as mentioned above for any sort of monetary or other valuable consideration that can be classified as a “sale” under California law.

Your Rights & Choices (“Options”)

In accordance with the rules set for by the CCPA, FlipScore Credit offers you (California resident) certain Options regarding your Personal Information. This section will list them out for you along with and explaining how you can exercise those rights.

  • Access to Specific Information and Data Portability Rights

You may request disclosure of certain information about our data collection and use of said data for the past 12 months. Upon receipt and confirmation of a verifiable consumer request from you, Flip Score Credit will disclose to you:

  • Categories of Personal Information collected about you
  • Categories of sources of said Personal Information FlipScore Credit has collected about you.
  • The original business and/or commercial purpose FlipScore Credit may have for collection of said data
  • The original business and/or commercial purpose FlipScore Credit may have for selling said data.
  • Categories of data as well as third parties with whom FlipScore Credit has shared Personal Information.
  • Any specific Personal Information FlipScore Credit collected about you. This is referred to as a data portability request.
  • Any data sold and/or disclosure of your Personal Information for any purpose. Two separate lists will be shared, each disclosing:
    • Categories of any Personal Information about you that FlipScore Credit may have sold over the past 12 months within the guidelines of CCPA as well as the categories of the third parties with whom said Personal Information is shared or sold other than business purposes; and
    • Categories of any Personal Information about you that FlipScore Credit disclosed for business purposes.
Deletion Request Rights

CCPA allows you the unchallenged right to request FlipScore Credit that we delete any and all Personal Information we may have collected or stored/retained, subject to a few exceptions. After FlipScore Credit receives a verifiable consumer request from you, we shall delete all your Personal Information from our records, unless an exception applies. FlipScore Credit shall also direct all third parties that said information may have been shared with in the normal course of business to do the same.

FlipScore Credit reserves the right to deny the deletion of Personal Information even in the presence of a formal verifiable consumer request, should retention of said Personal Information become absolutely necessary in order to:

  • Complete any business transaction for which the Personal Information was originally collected, provide any service that was requested by you, complete any actions that were initiated due to a reasonable anticipation or expectation of continuance or an ongoing business relationship with you, or otherwise perform the duties listed in FlipScore Credit’s contract with you.
  • Ensure data security, enhance protection against malicious, fraudulent, deceptive, or otherwise illegal activity.
  • Prosecute you in case of any illegal activity on your part.
  • Debug any products or service in order to identify and make any necessary repair errors that may have impaired functionality.
  • Ensure the right other customers can exercise their right to free speech in case removal of your Personal Information impedes it in any way, shape, or form.
  • Ensure that no rights are being violated of other consumers provided for by law.
  • Ensure maximum compliance with California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  • Enable internal uses aligned with any and all consumer expectations keeping your relationship with FlipScore Credit in mind.
  • Comply with any legal obligation imposed on FlipScore Credit by the local, state, or federal government.
Access, Data Portability, & Deletion Rights

By using FlipScore Credit, FlipScore Credit agree that only you or a person explicitly authorized by you can act on your behalf to make a verifiable consumer request to FlipScore Credit in relation to your Personal Information.

Under CCPA, you have the unchallenged right exercise unlimited access, portability, and deletion rights as described in the sections above. To do so, we recommend that you submit a formal request to us by:

  • Emailing *support email*, or
  • Visiting *CCPA request email/other contact email*

California rules and regulation as well as State law allows you to designate any authorized agent, provided they are of sound mind, to submit a verifiable consumer request in your stead. To make such an appointment, you shall give said agent a notarized permission (written) that explicitly states that they may act on your behalf when it comes to dealing with FlipScore Credit.

Agents must be of sound mind and would be subject to verification procedures just as you would be, i.e., the process we use to verify new consumers who have no existing relationship with FlipScore Credit. We have the right to request that, even though the agent has a notarized form, you shall provide some sort of verification in regards to your own identity. A simple phone call or perhaps a face-to-face meet would suffice. Should you be unavailable for that, FlipScore Credit shall turn to your next of kin for verification. Failure to provide verification, if requested, gives FlipScore Credit the right to reject said agency.

In case of a minor, parents or guardians are allowed by law to make a verifiable consumer request on their behalf. However, it is important to understand that in regards to minors, the CCPA imposes strict regulations about enforcing your own decisions on the minor. Therefore FlipScore Credit has the unchallenged right to ask you that you sign and submit a notarized consent form when doing so. We also reserve the right to consult with the minor to ask whether this decision has been made with their consent.

The verifiable consumer request must include:

  • Sufficient information that leaves no room for uncertainty and allows FlipScore Credit to make reasonable verification suggesting that you are indeed the consumer whose Personal Information we have collected.
  • Explain in detail your request for FlipScore Credit to properly understand, evaluate, and respond.
Verifying Your Request

Without proper verification, FlipScore Credit can and will not respond to any requests made in regards to Personal Information. FlipScore Credit will make every reasonable effort to verify your request but no expectation of going above and beyond should be made.

In case of failure to verify the identity of agent or the real consumer, FlipScore Credit will take no discernable action, and in case we do, out response will be limited to the bare minimum as required by applicable legislation. Please keep in mind that in order to make a verifiable consumer request, you do not have to create an account with us.

Response Timing and Format

FlipScore Credit endeavors to make every effort to respond to any and all verifiable consumer request at most 45 days after the day of receipt. In case FlipScore Credit requires more time, we shall inform you in writing or otherwise for an extension of up to 90 days. For those applicants who have an account with FlipScore Credit, you shall get the written message delivered to that account.

For those applicants who do not have an existing FlipScore Credit account, the same shall be delivered via mail. You shall choose whether you prefer electronic or physical mail.

In case the answer is negative, the response shall include an explanation of why FlipScore Credit cannot or is not willing to comply to your request.

FlipScore Credit charges no fee for processing or responding to any verifiable consumer request unless it involves excessive efforts from our end, is repetitive, or outstandingly ill- or unfounded. In case FlipScore Credit determines that your request warrants a fee, our email/mail will contain information about our decision along with the cost estimate.

As required by law.

Notwithstanding any provision set forth in the Contract Agreement, the Terms of Use, or this Addendum, FlipScore Credit reserves the right to cooperate with law enforcement or government agencies for any well-founded reason that may arise in relation to any conduct or activity on your behalf that we believe, in good faith, violates any local, state, federal, or international law.

Accessibility

For those customers who use any sort of assistive technology and are unable to see, read, understand, or otherwise make sense of this Statement and the information contained within, Flip Score Credit recommends that you get in touch with us at *email address*. We shall make every effort to get in touch with you, so we request that you indicate your preferred format in which we should send you the same material and mode of communication, i.e., contact information.

Contact Information

For any questions or comments in regards to this Statement, your Agreement with FlipScore Credit, our Personal Information collection and usage poilicies, your rights under this Statement and CCPA and options about such use, or are looking to exercise the rights provided to you under California law, please get in touch with us at *email address*.