Legal
Privacy Statement
Effective Date: June 1, 2021
Last Reviewed on: June 1, 2021
Smart Source Capital (“SSC”) respects your privacy and provides this Privacy Notice (“Privacy Notice”) to help you understand how we obtain and process your personal information. We encourage you to read this Privacy Notice carefully so that you can understand our policies and make informed choices regarding your personal information. This Privacy Notice applies to all visitors and users of this website. By your access or use of this website, you understand and consent to our policies and practices.
This Privacy Notice does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by any third party.
- Any third party, including through any application or content that may link to or be accessible from our website.
We reserve the right to amend this Privacy Notice at our discretion and the information contained here may change from time to time. Your continued use of our website will be deemed acceptance of any changes. We advise you to check this Privacy Notice periodically for any updates or revisions.
I. Personal Information.
We refer to personal information generally as data that can be reasonably linked with or used to identify you. Personal information includes your contact information, demographic information, social security number, driver’s license, and/or financial information.
Please be advised that personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from any statutory definition of personal information, including, and not limited to, information covered by sector-specific privacy laws such as the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), or the Driver’s Privacy Protection Act of 1994.
This website is not intended for children who are under 13 years of age. We do not knowingly collect any information from children who are under the age of 13. If you are under 13 years of age, do not use or provide any information on this website, register on the website, or provide any information about yourself to us. If we learn that we have received personal information from a child under 13, we will delete that information.
II. How We Receive and Process Your Personal Information.
SSC does not collect any personal information from you through our website unless you voluntarily provide such information to us. How we receive and process your personal information depends on the nature of your relationship with SSC.
SSC may have collected the following categories of personal information from you within the last twelve (12) months:
- Identifiers. Information that may be used to identify you as a consumer such as your real name, alias, postal address, email address, unique personal or online identifier, IP address, account name, Social Security number, driver’s license or passport number, telephone number, employment history, bank account number, or financial records. For example, when you submit a loan application, you voluntarily provide us with your contact information so that we can process and respond to your inquiry.
- Protected classifications. Information including your race, national origin, religion, gender, disabilities, veteran or military status. We may be required to collect such information to ensure our compliance with fair lending laws.
- Professional or employment-related information. If you submitted a job application to be considered for employment, we may retain personal information such as current or past employment-related information.
We obtain the categories of personal information listed above directly from you when you voluntarily provide it to us, including information that you submit through our website. For example, we process data that you input and transmit via the Borrower portal.
III. Use of Personal Information.
SSC only uses your personal information in connection with legitimate business purposes or to ensure our compliance with applicable law. We may use or disclose personal information we collect for one or more of the following purposes:
- To accomplish and fulfill the purpose for which you provided us the information. For example, if you contact us with an inquiry about our products, we may ask that you provide your name and contact information so that we can respond to and follow-up on your request.
- To process your requests, transactions, and prevent transactional fraud;
- To improve our communications with you and to deliver content, product, and/or services that are relevant to your interests.
- To detect or prevent security incidents or other illegal activity and prosecuting the responsible parties.
- To respond to law enforcement requests, court orders, or governmental regulations.
We will not collect additional categories of personal information or use the personal information collected for materially different, unrelated, or incompatible purposes without providing you with notice or obtaining your consent.
IV. Disclosure of Personal Information.
SSC will only disclose your personal information to our affiliates and/or nonaffiliated parties for legitimate business purposes or as required by law. We do not sell your personal information. We may share your personal information with the third-party service providers to fulfil the purpose for which you provided us the information. For example, we may work with a title solution company to verify your ownership of property within the ordinary course of reviewing borrower applications.
V. Your Rights and Choices.
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. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business purpose for using your personal information.
- The categories of third parties with whom we share that personal information.
It is entirely your choice to provide SSC with your personal information and you have no obligation to do so. Note that if you choose not to share your personal information with us, we may be unable to provide you services where such information is required.
VI. Deletion Request Rights and Exceptions.
You have the right to request that we delete your personal information, subject to certain exceptions as described in this section. In order for us to
process and honor your request, we must be able to reasonably verify your identity. Your deletion request may be denied or delayed if we are unable to verify your identity.
Once we receive and confirm your verifiable consumer request, we will honor your request unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us, our affiliates, or our service providers to:
- Complete the transaction for which we collected the personal information, fulfil a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or assist in the prosecution of those responsible for such activities.
- Identify and/or repair errors in our systems that impair existing intended functionality.
- Reserve and/or exercise any right(s) as provided for by law.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with any legal obligation(s).
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
VII. Exercising Access, Data Portability, and Deletion Rights.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. For purposes of verifying your identity, we will need you to verbally provide data points matching the personal information in our possession.
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 verifiable consumer request to confirm the requestor’s identity or authority to make the request.
VIII. Response Timing and Format.
We will use reasonable efforts to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
