California Privacy Notice

Scope of this notice

This notice applies to personal information Oppur2nity LLC collects through EzApply websites, online request forms, communications, and related services. It applies only to California residents and only where the information and activity are subject to the CCPA.

EzApply is not a lender. We provide an online lead-generation and advertising service that may connect a consumer’s request with participating lenders, providers, or lead aggregators. Those recipients have their own privacy practices and are responsible for their own products, decisions, and accounts.

Personal information we collect

Depending on how you interact with EzApply, we have collected or may collect the following categories of personal information during the preceding 12 months:

• Identifiers and customer-record information: name, alias, postal address, email address, telephone number, IP address, date of birth, Social Security number, driver license information, and similar identifiers.
• Protected classification information: age and military or veteran status, and other classification information you choose or are required to provide.
• Commercial and financial information: requested amount, housing status, debt range, vehicle status, bank name, routing and account numbers, income range, pay method, pay frequency, next pay date, and information about products or services requested, considered, or offered.
• Internet or network activity: browser and device information, user agent, referring and landing pages, interactions with forms and advertisements, funnel events, consent records, and related technical activity.
• Geolocation information: street address, city, state, and ZIP code. EzApply does not request precise GPS location through the loan-request form.
• Professional or employment information: employment status and length, employer name and telephone number, job title, income source, and related information.
• Inferences: eligibility, matching, routing, fraud-prevention, and marketing information derived from the details submitted or from interactions with the service.
• Sensitive personal information: Social Security number, driver license number, account and routing numbers, financial information, and credentials or identifiers used to verify identity.

EzApply does not intentionally collect biometric templates, sensory data, or non-public education records through its standard request form. Personal information does not include information excluded from the CCPA, such as qualifying deidentified, aggregated, or publicly available information.

Sources of personal information

• Directly from you, including information entered into forms or provided in communications.
• Automatically from your browser or device when you use the website.
• From participating lenders, providers, lead aggregators, affiliates, advertising partners, compliance vendors, and service providers.
• From fraud-prevention, identity-verification, analytics, data-validation, and marketing sources where permitted by law.

How we use personal information

• To receive, validate, process, route, and respond to a loan or service request.
• To connect requests with participating lenders, providers, or lead aggregators and communicate request updates.
• To verify identity, income, employment, banking details, consent, eligibility, and information accuracy.
• To prevent fraud, abuse, security incidents, duplicate submissions, and other unlawful activity.
• To operate, secure, troubleshoot, analyze, personalize, and improve EzApply and related services.
• To provide advertising or marketing communications when permitted and to honor opt-out and suppression choices.
• To comply with law, legal process, audits, regulatory obligations, contracts, and enforcement requests.
• To evaluate or complete a merger, financing, acquisition, restructuring, bankruptcy, or transfer of business assets.
• For another compatible purpose disclosed when the information is collected or with your direction or consent.

How we disclose personal information

We may disclose the categories described above to participating lenders, financial-service providers, lead aggregators, affiliates, service providers, compliance and consent vendors, identity and fraud-prevention vendors, hosting and security providers, analytics or advertising partners, professional advisers, government authorities, and parties involved in a business transaction.

A recipient may use information to evaluate or respond to a request, verify details, provide services, prevent fraud, comply with law, or market products where permitted. A recipient may also have an independent relationship with you. Review the recipient’s disclosures before accepting an offer or providing additional information.

Sale or sharing of personal information

EzApply is a for-profit advertising and lead-generation service. In the preceding 12 months, transfers of request information to participating providers, lead aggregators, or marketing partners may have constituted a “sale” under the CCPA. Categories involved may include identifiers, customer-record information, protected classifications, commercial information, internet activity, geolocation information, professional information, and inferences.

Identifiers and internet activity may also be shared for cross-context behavioral advertising where advertising technology is used. EzApply does not knowingly sell or share personal information belonging to anyone under 16.

Sensitive personal information may be disclosed to providers and vendors to process a request, verify identity, prevent fraud, or provide a requested service. We do not use sensitive personal information for the purpose of inferring characteristics about you. Where California law gives you a right to limit a particular use or disclosure, you may submit that request using the methods below.

Your California privacy rights

• Right to know and access: request the categories, sources, purposes, recipient categories, and specific pieces of personal information we maintain about you. Where required, a request may cover retained information collected on or after January 1, 2022.
• Right to delete: request deletion of personal information, subject to legal and operational exceptions.
• Right to correct: request correction of inaccurate personal information we maintain about you.
• Right to opt out: direct us not to sell personal information or share it for cross-context behavioral advertising.
• Right to limit: where applicable, direct us to limit certain uses or disclosures of sensitive personal information.
• Right to non-discrimination: exercise your CCPA rights without unlawful discriminatory treatment.

Exercise your rights

Requests to know, delete, correct, or limit

Mail a written request to Oppur2nity LLC, Attn: Privacy Department, 30 N Gould St. Ste N, Sheridan, WY 82801. State the right you want to exercise and provide your first and last name, email address, telephone number, and enough additional information to locate your record. Do not send a Social Security number, full bank-account number, password, or original identity document.

Only you or an authorized agent may submit a verifiable request concerning your personal information. We will use information supplied with a request only to verify, locate, and process that request. We may be unable to fulfill a request if we cannot reasonably verify your identity or authority, locate the information, or if an exception applies.

Authorized agents

An authorized agent may submit a request on your behalf. We may require proof that you authorized the agent, ask you to confirm the authorization directly, or require the agent to show a valid power of attorney. We may also require you to verify your identity when the law permits.

Response timing and appeals

For requests to know, delete, or correct, we generally confirm receipt within 10 business days and respond within 45 calendar days. When reasonably necessary, we may extend the response period by an additional 45 days and will explain the extension. We process opt-out and applicable sensitive-information limitation requests as soon as reasonably feasible and generally within 15 business days.

Requests are ordinarily processed without charge. If a request is manifestly unfounded, excessive, or repetitive, we may charge a reasonable fee or decline the request as permitted by law. If we deny a request, our response will explain the basis and any available method to challenge the decision.

Retention

We retain each category of personal information only for as long as reasonably necessary for the purpose for which it was collected or another disclosed, compatible purpose. Retention criteria include the time needed to process and document a request, maintain consent and transaction records, honor suppression choices, meet contractual and legal obligations, resolve disputes, prevent fraud, protect security, and enforce agreements. Retention periods may vary by record type and applicable law. When information is no longer reasonably necessary, we may delete, deidentify, or aggregate it.

Deletion exceptions

We may retain information when permitted or required to complete a requested transaction, maintain security and integrity, detect or prosecute fraud or illegal activity, debug or repair errors, exercise legal rights, comply with law, preserve evidence, conduct qualifying research, or make another internal use compatible with the context in which the information was provided. We will explain an applicable exception when required.

Children

EzApply is intended only for adults who are at least 18 years old. We do not knowingly collect personal information from children and do not knowingly sell or share personal information belonging to anyone under 16. If you believe a child provided information, contact the Privacy Department using the address below.

Other California rights

California Civil Code section 1798.83, commonly called the “Shine the Light” law, may permit California residents to request information about certain disclosures of personal information to third parties for their direct-marketing purposes. Submit a written request to the Privacy Department at the address below.

Accessibility and alternative formats

If you have a disability and need this notice in an alternative format, mail a request describing the format needed to the Privacy Department. We will work with you to provide reasonable access.

Changes to this notice

We may update this notice to reflect changes in our practices, technology, services, or legal obligations. When we make changes, we will post the revised notice and update the effective date. Material changes will be communicated as required by law.

Contact the Privacy Department

Oppur2nity LLC, Attn: Privacy Department, 30 N Gould St. Ste N, Sheridan, WY 82801.

Do not send Social Security numbers, full bank-account information, passwords, or original identity documents through ordinary mail or any unsecured communication channel.