California Consumer Privacy Act Disclosure

Effective: January 1, 2020

This California Consumer Privacy Act Disclosure (“CCPA Disclosure”) explains how SilentJourney Financial Corporation and its U.S. affiliates (collectively, “SilentJourney,” “we,” “us,” or “our”) collect, use, and disclose personal information subject to the California Consumer Privacy Act (“CCPA”). It also describes the privacy rights of California residents under the CCPA and how they can exercise those rights.

This CCPA Disclosure applies solely to California residents and supplements any other privacy policies or notices applicable to the SilentJourney services that you visit or use.


What Personal Information Is Covered by the CCPA?

Under the CCPA, “personal information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

The CCPA does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, and certain other state or federal privacy laws. For example, this CCPA Disclosure does not apply to information that we collect about individuals who seek, apply for, or obtain our financial products and services for personal, family, or household purposes, which is subject to our U.S. Consumer Privacy Notice, or other financial privacy notice applicable to the SilentJourney services that you visit or use.

This CCPA Disclosure also does not apply to information that we collect in connection with providing products or services to other businesses (such as our commercial or small business customers) or when receiving products or services from our suppliers. Similarly, it does not apply to information we collect in the context of a person’s role as a job applicant, employee, associate, contractor, or other member of the SilentJourney workforce, which is subject to our SilentJourney Workforce CCPA Disclosure.


Categories of Personal Information we collect

Most of the information we have collected has been collected in the context of providing financial products and services, and is therefore not subject to the CCPA. We also collect personal information relating to California residents in other contexts, including in connection with our marketing activities, our websites and mobile applications, and certain SilentJourney locations (such as when you use guest WiFi at a SilentJourney Cafe).

In the past 12 months, we have collected the following categories of personal information, as defined in the CCPA, relating to California residents. The categories of personal information that we collect, use, and disclose about a California resident will depend on our specific relationship or interaction with that individual, and the examples provided in each category below are for illustrative purposes only.

CCPA Categories Illustrative Examples
Identifiers Name, address, email address, online identifiers, internet protocol address, Social Security numbers, or other similar identifiers

Personal information

as defined in the California Customer Records Act, Cal. Civ. Code § 1798.80

Contact and financial information
Protected classifications under California or federal law Age, marital status, sex, and veteran or military status
Commercial information Information about past transactions or purchases
Biometric information Behavioral characteristics derived from interactions with our websites or mobile apps
Internet or similar network activity information Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement
Geolocation data Device location
Audio, electronic, visual, or similar information Call and video recordings
Inferences drawn from other personal information Certain inferences concerning an individual’s preferences and characteristics

Categories of Sources of Personal Information

In the past 12 months, we have collected personal information relating to California residents from the following sources:

  • Directly from you
  • Affiliates
  • Business partners
  • Service providers
  • Consumer data resellers
  • Third parties that you have authorized or directed to share information with us
  • Government entities from which public records are obtained

Purposes for which We Use Personal Information

Most of the information we use is in the context of providing financial products and services, and is therefore not subject to the CCPA. We may use personal information relating to California residents for one or more of the following business purposes:

  • Providing and maintaining our products and services
  • Verifying your identity
  • Detecting and preventing fraud
  • Protecting against security risks
  • Advertising and marketing
  • Conducting research and data analysis
  • Maintaining our facilities, systems, and infrastructure
  • Improving our products and services
  • Carrying out our legal and business purposes, such as complying with federal, state, or local laws, responding to civil, criminal, or regulatory lawsuits or investigations, exercising our rights or defending against legal claims, resolving complaints and disputes, performing compliance activities, performing institutional risk control, and otherwise operating, managing, and maintaining our business
  • As otherwise disclosed to you at or before the point of collecting your personal information

We may also use personal information relating to California residents for one or more of the specific “business purposes” listed in the CCPA:

  • Certain auditing and measurement purposes, such as counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with applicable standards
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
  • Debugging to identify and repair errors that impair existing intended functionality
  • Short-term, transient use
  • Performing services on behalf of SilentJourney or its service providers, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of SilentJourney or its service providers
  • Undertaking internal research for technological development and demonstration
  • Undertaking activities to verify or maintain the quality or safety of a service that is owned or controlled by SilentJourney, and to improve, upgrade, or enhance the service that is owned or controlled by SilentJourney

Disclosure of Personal Information to Third Parties

In the past 12 months, we have disclosed each of the above-listed categories of personal information for our business purposes to one or more of the following categories of third parties:

  • Affiliates
  • Business partners
  • Service providers
  • Third parties with whom you authorize or direct us to share your information
  • Government entities and others with whom we share information for legal or necessary purposes

In addition, the SilentJourney Online Privacy Policy describes how we and third-party providers use a variety of online tools and technologies to collect information when you visit or use certain SilentJourney online services and provides information about how to opt out of certain targeted advertising.

In the past 12 months, we have not shared personal information relating to California residents in a manner that we consider a sale within the meaning of the CCPA.


Rights Under the CCPA

If you are a California resident, you may request that we disclose to you the following information covering the 12 months preceding your request:

  • The categories of personal information described above that we have collected about you and the categories of sources from which we collected such personal information
  • The business or commercial purposes for collecting such personal information
  • The categories of personal information about you that we have disclosed to third parties for a business purpose and the categories of third parties to whom we have disclosed such personal information
  • The specific pieces (e.g., copies) of personal information we have collected about you

California residents also have the right to submit a request for deletion of personal information under certain circumstances, although there may be legal or other reasons that SilentJourney will retain your information.

In some instances, we may decline to honor your request. For example, we may decline to honor your request if we cannot verify your identity or confirm that the personal information that we maintain relates to you, or if we cannot verify that you have the authority to make a request on behalf of another individual. In other instances, we may decline to honor your request where an exception applies, such as where the disclosure of personal information would adversely affect the rights and freedoms of another consumer or where the personal information that we maintain about you is not subject to the CCPA. Nonetheless, you have the right to be free from unlawful discrimination for exercising your rights under the CCPA.


How to Make Requests

If you are a California resident and would like to exercise the rights described above, please submit your request by:

Once we receive your request, we may verify your identity through your account or by requesting information sufficient to confirm your identity. If you would like to use an agent to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf, in addition to verifying your identity or the identity of your agent.


Changes to This California Consumer Privacy Act Disclosure

We may change or update this CCPA Disclosure in the future. When we do, we will post the revised CCPA Disclosure on our website. This CCPA Disclosure was last updated and became effective on the date posted at the top of this page.


Contact Us

If you have questions about this CCPA Disclosure or our privacy practices, please visit silentjourney.com/privacypolicy.html or contact us at Customer Support.

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