California Privacy Notice
Last updated May, 2024
Zendable, Inc. and its affiliates (collectively, "Zendable", "we", "us", "our") are committed to your privacy and security online. This California Privacy Notice (“Notice”) provides information to California residents whose personal information is processed pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act ( collectively “CCPA”). This Privacy Notice describes the categories of personal information we collect, the purposes for which that information is collected, a summary of the rights you have and how to exercise these rights and applies to personal information collected from California residents (“you” or “your”) who have a business relationship with us or who are prospective customers.
This Privacy Notice does not apply to personal information that is protected under the Gramm-Leach-Bliley Act, a federal financial privacy law, as set out in our U.S. Consumer Privacy Notice. It also does not apply to personal information relating to job applicants or employees that are California residents. Thus, if you are using our product or service primarily for personal, family or household purposes or you are a California resident and you have applied for a job with us, you would not be covered by this Privacy Notice.
If this CA Privacy Notice applies to your relationship with us, please see the section below titled “Your Privacy Rights” to learn more about the rights you may have under California law.
We may change or update this Notice periodically. When we do, we will post the revised Notice on this webpage indicating when the Notice was "Last Updated."
Categories of Personal Information We Collect
Personal information is any information that identifies or could reasonably be linked with a particular individual or household. Personal information does not include information that is publicly available or has been de-identified or aggregated. Where we maintain or use deidentified information, we will continue to maintain and use the deidentified information only in a deidentified fashion and will not attempt to re-identify the information.
Depending on the nature of your relationship with us, we may have collected the following categories of personal information, including sensitive personal information, about you during the preceding 12 months:
- Personal Identifiers, such as name, postal address, email address, account name, social security number, driver’s license or state identification card number, passport number or telephone number
- Personal Information, such as information that identifies, relates to or is capable of being associated with, a particular individual, such as name, passport number, driver’s license or credit card number, bank account number or other financial information
- Characteristics of Protected Class under California or federal law such as date of birth, sex/gender or marital status
- Purchase Information, such as products and services obtained and transaction histories
- Biometric Information, such as fingerprints and voiceprint
- Internet Information, such as online information (e.g., browsing history) and information regarding interaction with our websites, applications, or advertisements
- Geolocation Data, such as device location
- Audio and Visual Information, such as audio, electronic, visual, thermal, olfactory, or similar information, such as call and video recording
- Employment Information, such as work history and prior employer, information from background checks, resumes, and personnel files
- Education Information, that may be subject to the federal Family Educational Rights and Privacy Act, such as student records and confirmation of graduation
- Inferences that may be based on information about an individual to create a summary about, for example, an individual’s preferences and characteristics.
We may also collect the following information that may be considered “Sensitive Personal Information” under the CCPA: your Social Security number, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; your precise geolocation; your racial or ethnic origin, religious or philosophical beliefs, citizenship, or immigration status; and biometric information processed to uniquely identify an individual.
Sources of Personal Information
The sources from which we collect personal information depend on our relationship or interaction with a specific California resident. Listed below are the categories of sources from which we collect personal information in different contexts.
- From California residents directly, or other individuals acting on their behalf.
- Public records or widely available sources, including information from the media, and other information made available by federal, state, and local government entities.
- Outside organizations that provide data to support activities such as fraud prevention, underwriting, and marketing, such as internet service providers, social networks, operating systems and platforms, data brokers, advertising networks, and data analytics providers.
- Outside companies or organizations from whom we collect personal information as part of providing products and services, completing transactions, supporting our everyday operations, or business management and development. Examples include companies or organizations to whom we provide products or services; other parties, partners, and financial institutions; and parties involved with mergers, acquisitions, and other transactions involving transfers of all or part of a business, or a set of assets.
Why We Collect Personal Information and How We Use and Disclose It
The purposes for which we collect, use, and disclose personal information depend on, among other things, our relationship or interaction with a specific California resident. The table below lists the purposes for which we collect, use, and disclose personal information in different contexts.
Purposes for Collection, Use and Disclosure | Examples |
|---|---|
Provide and manage products and services |
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Support our everyday operations, including to meet risk, legal, and compliance requirements |
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Manage, improve, and develop our business |
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Sensitive Personal Information as permitted by law |
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Categories of Third Parties With Whom We Disclose Personal Information
The categories of third parties to whom we disclose personal information about a specific individual depend on, among other things, our relationship or interaction with a specific California resident. Such third parties include:
- Outside companies or organizations, including service providers subject to appropriate confidentiality and use restrictions, to whom we disclose personal information as part of providing products and services, completing transactions, supporting our everyday operations, or business management and development.
- Examples may include internet service providers, social networks, operating systems and platforms, data brokers, advertising networks, and data analytics providers; companies or organizations to whom we provide products or services; other parties, partners, and financial institutions; and parties involved with mergers, acquisitions, and other transactions involving transfers of all or part of a business, or a set of assets.
- Government agencies including to support regulatory and legal requirements
- Companies or individuals representing California residents such as an accountant, financial advisor, or person holding power of attorney on behalf of a California resident
- Outside companies or organizations, in connection with routine or required reporting, including consumer reporting agencies and other parties
- Other parties, if you specifically direct or expressly consent to us disclosing your personal information to them
For each personal information category we have collected, the categories of third parties to whom we disclosed for our business purposes information from that personal information category during the preceding 12 months include:
- Outside organizations in connection with providing products and services, completing transactions, supporting our everyday operations, or business management and development
- Outside companies in connection with routine or required reporting
Data Retention
We take reasonable steps designed to ensure that your personal information is only processed for the minimum period necessary for the purposes set out in this disclosure. We will retain copies of your personal information in a form that permits identification only for as long as: (a) we maintain an ongoing relationship with you (e.g., while you are still receiving services from us); or (b) your personal information is necessary in connection with purposes set out in this disclosure, plus the duration of any applicable limitation period under applicable law; and where required by applicable law or a retention policy established in accordance with applicable law.
In addition, if any relevant legal claims are anticipated/brought, we may continue to retain your personal information for such additional periods as are necessary in connection with that claim. Once the periods above have concluded, each to the extent applicable or permitted by applicable law, we will permanently delete or destroy the relevant personal information, or archive your personal information so that it is beyond use, or anonymize the relevant personal information.
Requests Under the CCPA
As a California resident, you may have certain rights over the personal information we have about you pursuant to the CCPA. As outlined above, these rights do not apply to individuals whose personal information is protected under the Gramm-Leach-Bliley Act, as described in our U.S. Consumer Privacy Notice. We have no actual knowledge that we sell or share personal information of California residents 16 years of age and younger.
As a California resident, you may have one or more of the following rights under the CCPA:
- the right to know:
- the categories of personal information we have collected
- the categories of sources used to collect the personal information
- the business or commercial purposes for collecting your personal information
- the categories of recipients with whom we share your personal information, including for cross-contextual behavioral advertising purposes and
- the specific pieces of personal information we have collected about you
- the right, in certain circumstances, to correct inaccurate personal information we collected about you
- the right to request, on legitimate grounds, deletion of your personal information that we collected
- the right to opt out of the sale of your personal information
- The CCPA defines a "sale" as the disclosure of personal information for monetary or other valuable consideration. We do not sell and have not sold, within at least the last 12 months, any personal information.
- the right to opt out of the sharing your personal information for the purpose of cross contextual behavioral advertising
- We do not share personal information for cross-context behavioral advertising within the scope of CCPA.
- the right to limit the use and disclosure of your Sensitive Personal Information.
- We do not collect or process sensitive personal information for the purpose of inferring characteristics about you and therefore do not offer the choice to limit the use or disclosure of sensitive personal information.
- We do not “sell” or “share” sensitive personal information for purposes of cross-context behavioral advertising.
- the right not to be discriminated against for exercising any of these rights.
We also must provide in this online disclosure certain details about our collection and handling of categories of personal information. Please note, not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity.
If you are a California resident, you can make a rights request by emailing us at support@zable.com or calling us at 1-844-779-2253. Before fulfilling your request, we must verify the personal information we already have on file to confirm your identity. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.
If you are a California resident, you may authorize an agent to make a request on your behalf. A California resident’s authorized agent may make a request on behalf of the California resident by using the submission methods listed above. As part of our verification process, we may request that you provide, as applicable:
- For an individual ("requestor") making a request on behalf of a California resident:
- The requestor's name; contact information; social security or individual taxpayer identification number; date of birth; and Driver’s License, State ID, or Matricula Card.
- The name; contact information; social security or individual taxpayer identification number; date of birth; and Driver’s License, State ID, or Matricula Card of the California resident on whose behalf the request is being made.
- A document to confirm that the requestor is authorized to make the request. We may accept, as applicable, a signed permission by the California resident on whose behalf the request is made, copy of a power of attorney, legal guardianship or conservatorship order, or a birth certificate of a minor if the requestor is the custodial parent.
- For a company or organization ("legal entity requestor") making a request on behalf of a California resident:
- The legal entity requestor’s active registration with the California Secretary of State.
- Proof that the California resident has authorized the legal entity requestor to make the request. We accept as applicable, a signed permission by the California resident on whose behalf the request is made, copy of power of attorney, or legal guardianship or conservatorship order.
- The name; contact information; Social Security or individual taxpayer identification number; data of birth; and driver’s license, state ID, or matricula card of the California resident on whose behalf the request is being made. From the individual who is acting on behalf of the legal entity requestor, proof that the individual is authorized by the legal entity requestor to make the request. We accept a letter on the legal entity requestor’s letterhead, signed by an officer of the organization. We provide a template to use via the URL provided above for making requests.
Do Not Track
Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our website does not currently process or respond to “DNT” signals.
Contact Us
If you have questions or concerns regarding this policy, you should contact us by emailing us at privacy@zable.com, by calling us at 1-844-779-2253 during our operating hours 9:00 AM EST to 4:00 PM EST for credit cards or 9:00 AM EST to 5:30 PM EST for loans, Monday through Friday, or by writing to us via regular mail at Zendable, 413 West 14th Street, Spaces Suite 208, New York, NY 10014.