Privacy Notice For California Residents

This Privacy Notice for California residents (“Notice”) supplements Hillspring Financial, Inc’s Privacy Notice and applies to all individuals who reside in California (“consumers,” “you,” or “your”).  For the purpose of this Notice, personal information does not include information that is exempted from the CCPA, such as personal information covered by other privacy laws such as the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, or the California Financial Information Privacy Act. Depending on whether you have or had a business relationship with us, the CCPA may not apply to you or all of your personal information.

Personal Information We Collect

We have collected the following categories of personal information (collected and used solely within the context of California residents’ roles, as listed here) from consumers (including consumers who are job applicants to or employees, owners, directors, officers, or contractors of Hillspring Financial, Inc.) within the last 12 months:  Identifiers such as real name, postal address, email address, telephone number, online identifiers, Internet Protocol address, driver’s license number, Social Security number, passport number, government issued identification, or other similar identifiers; Protected classification characteristics under California or federal law such as age and gender; Financial and commercial information such as investment background and experience, as well as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; Internet or other network activity information such as information regarding your interaction with our website and applications.  Professional or employment related information, which includes information necessary to conduct background screenings; and inferences drawn from such information.

Sources of Personal Information

We collect the categories of personal information listed above from the following categories of sources:  Directly from you or those acting on your behalf. For example, from forms you complete online when you request information about or obtain our services, and information that is automatically collected from internet or other network activity regarding your interaction with our websites and applications; and Government entities from which public records are maintained and other publicly available sources and unaffiliated service providers.

How We Use Your Information

We have used or disclosed the personal information collected for one or more of the following business purposes within the last 12 months (excluding uses or disclosures we may be prohibited from reporting under applicable law): To conduct our business and where necessary in order to assist us in verifying your identity, and to provide support, personalize, and develop our services; To fulfill and respond to your inquiries and requests, including providing you with support, investigating and addressing your concerns  and to otherwise carry out the purposes for which you provided the information; To perform in connection with your roles, responsibilities, and/or status as a job applicant to or an employee, owner, director, officer or contractor of Hillspring Financial, Inc., including administering payroll, benefits, maintaining compliance with policies and procedures, and to comply with health and safety and occupational health obligations; To help maintain the safety, security, and integrity of our business, including all services, and to respond, where necessary, to requests from regulators and law enforcement or as otherwise required by applicable law, regulation, court order, or similar demand; As described to you when collecting your personal information or as otherwise set forth in the CCPA; and to evaluate or conduct a merger, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Hillspring Financial, Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Hillspring Financial, Inc. is among the assets or business operations transferred.

Personal Information Disclosed for Business Purposes

We have disclosed the categories of personal information listed above for business purposes to the following categories of parties within the last 12 months (excluding disclosures we may be prohibited from reporting under applicable law): Our affiliated entities and unaffiliated service providers to help conduct our business; and Third parties to whom you direct or authorize us to disclose your personal information, independent of or in connection with services we provide to you. Hillspring Financial, Inc. does not and will not sell your personal information.

Your CCPA Data Rights

The CCPA provides consumers with certain data rights with respect to the personal information businesses collect. You may exercise any of the listed data rights (subject to certain exceptions and limitations), by following the “Instructions for Submitting a Verifiable CCPA Data-Rights Request” provided below.

You have “Rights to Know”:

  • The specific pieces of personal information we have collected about you;
  • The categories of personal information we have collected about you;
  • The categories of sources from which your personal information is collected;
  • The categories of personal information that we have disclosed for a business purpose about you;
  • The categories of third parties to whom personal information was disclosed for a business purpose; and
  • The business or commercial purpose for collecting personal information.
  • You also have the right to “Request to Delete” your personal information: You may request that we delete personal information about you that we have collected from you (unless an exception applies or deletion is otherwise restricted or prohibited by law, rule, or regulation).

Instructions for Submitting a Verifiable CCPA Data-Rights Request

Please following these instructions carefully.

You may submit a verifiable request to us by either calling our toll-free number or online. What to expect once you submit a request. We will work to confirm receipt of your request within 10 days (and provide you with information on how we will process your request, including our verification process) and to respond to your request within 45 days from the date of our receipt of your request (unless additional time is necessary, and, in such cases, we will explain to you the reason it may take more than 45 days to respond). We may ask you to provide additional information in order to verify your identity. We will only use any additional information we collect for the purposes of verifying your identity and for security or fraud-prevention purposes. In cases where additional information is required and we are unable to contact you with the contact information you have provided, we may be unable to respond to your request.

TOLL-FREE NUMBER ONLINE SUBMISSIONS

Call us at 800-264-0893 to submit your request.

If you are a current Hillspring Financial, Inc. client (or an agent with your own account-access credentials acting on behalf of a current Hillspring Financial, Inc. client) or a previous client, you may submit your CCPA data-rights requests through Hillspring Financial, Inc.’s secure Message Center and state the specific data rights requests you are making.  Please refer to the list of available data rights above.  Please do not provide any additional information. We will contact you directly or provide you with additional instructions.

Authorized Agents

A consumer can designate an authorized agent to make a data-rights request under the CCPA on the consumer’s behalf.  Who is an “authorized agent”? An authorized agent is a person or a business entity registered with the California Secretary of State that a consumer has authorized to act on their behalf. If you are an authorized agent and submit a data-rights request on behalf of a consumer, we may require that the consumer provide you with written authorization to make the request on their behalf and verify their own identity directly with us.

Non-Discrimination

You have the right not to receive discriminatory treatment for exercising any of these data rights. Hillspring Financial, Inc. does not discriminate against any consumer for exercising their rights under the CCPA.

CCPA Data Rights Are Not Available for Certain Personal Information

CCPA data rights are not available for personal information we collect about you in the course of you acting as a job applicant to or an employee, owner, director, officer, or contractor of Hillspring Financial, Inc. including, in these contexts, your emergency contact information and personal information that is necessary for us to retain to administer benefits for another person relating to you acting as a job applicant to or an employee, owner, director, officer, or contractor of Hillspring Financial, Inc. Any personal information we collect and use will only be used within the context of your role or former role in these capacities. Questions

If you have any questions or comments about this Notice or any of Hillspring Financial Inc.’s other privacy policies and practices, please call 800-264-0893 or go to www.hillspringfinancial.com/privacy. Information privacy and security is a partnership and a key aspect of our business.  We recognize data privacy is an ongoing responsibility. We reserve the right to update or amend this Notice from time to time and any such updates or amendments will be reflected in the Notice available on our website. We adopt this Notice to comply with CCPA Section 1798.130(a)(5). Last Updated: January 1, 2020 Notice to California Users Required by State Law. The information in this material is not intended as tax or legal advice. Please consult legal or tax professionals for specific information regarding your individual situation.