The state of California requires that we provide privacy information for individuals that reside in California. If you do not reside in California, you can skip this document.

For California residents, here is a summary of what you will learn from these California disclosures and privacy policy:

1.Personal Information We Collect

  • 1.1. What personal information does not include
  • 1.2. How we obtain your personal information
  • 1.3. How we may use your personal information
  • 1.4. How we may share your personal information

2. Changes to our California disclosures and privacy policy

3. How to contact us

Below is the legal information we are required to share:

These CALIFORNIA EMPLOYEE CCPA DISCLOSURES AND PRIVACY POLICY supplement the Employee Handbook and govern the personal information collected, used and shared by Elevate Credit, Inc. and its affiliates (“Elevate,” “we,” “us,” or “our”) and apply to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this policy.

1. PERSONAL INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual consumer or device (“personal information”).

1.1. Personal information does not include:

• Publicly available information from government records

• De-identified or aggregated consumer information

• Information excluded from the CCPA, like:

  •  health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

1.2. How We Obtain Your Personal Information:

How we obtain your information
Directly from you.You enter or provide us with information, whether online or by email, phone or document upload. For example, your contact information that you provide, your application for a loan, or documents you provide to verify your identity.
Directly and indirectly from you based on activity on our website.For example, from submissions through our website or website usage details collected automatically.
From vendors or third-parties that interact with us in connection with the services we perform.For example, companies that work with us to market our products to you, credit reporting agencies from which we check your credit in connection with a submitted application, or other vendors that provide data we use in underwriting or in protecting you and our products from fraud and identity theft.

1.3. How We Use Your Personal Information:

We may use or disclose the personal information we collect for one or more of the following business purposes:

1. To fulfill or meet the reason for which the information is provided, including but not limited to:

  • a. To fulfill or meet the reason for which the information is provided.
  • b. To provide you with a decision on an employment application.
  • c. To provide you with employment benefits.
  • d. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.

2. Undertaking internal research for technological development and demonstration.

3. Debugging to identify and repair errors that impair existing intended functionality.

4. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

5. Auditing related to a current interaction with you.

6. Short-term, transient use provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction.

7. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

1.4. Who We Share Your Personal Information with for a Business or Commercial Purpose:

We may disclose your personal information to a service provider or third party for a business or commercial purpose. When we disclose personal information for a business or commercial purpose, we enter a contract that describes the purpose and requires the service provider to both keep that personal information confidential and not use it for any purpose except performing the contract. Examples of who we share with include:

  • Service providers, including but not limited to payroll processors
  • Third parties to whom you authorize us to disclose your personal information in connection with your employment position, including but not limited to benefits administrators.

1.5. Within the last 12 months we collected the categories of personal information listed below and shared it as follows:

Collected personal info
Category Examples Collected (Yes/No) Sources of Collected Personal Information (See Section 1.2 above) Business or Commercial Purpose for Sharing (Section 1.3 #1-7, above) Category of Third Parties (See Section 1.4 above)
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. YES You or from service providers and third-parties 1-7 Service providers and third-parties
B. Personal information. A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, Qemployment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. YES You or from service providers and third-parties 1-7 Service providers and third-parties
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). YES You or from service providers and third-parties 1-7 Service providers and third-parties
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES N/A N/A N/A
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO You or from service providers and third-parties 1-7 Service providers and third-parties
F. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. YES You or from service providers and third-parties 1-7 Service providers and third-partie
G. Geolocation data. Physical location or movements. YES You or from service providers and third-parties 1-7 Service providers and third-parties
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. YES You or from service providers and third-parties 1-7 Service providers and third-parties
I. Professional or employment-related information. Current or past job history or performance evaluations. YES You or from service providers and third-parties 1,4-7 Service providers and third-parties
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO You or from service providers and third-parties 1,4-7 Service providers and third-parties
K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO You or from service providers and third-parties 1,4-7 Service providers and third-parties

1.6. Sale of Personal Information:

We do not and will not sell your personal information. We do not and will not sell the Personal Information of minors under 16 years of age without affirmative authorization.

2. CHANGES TO OUR CALIFORNIA EMPLOYEE CCPA DISCLOSURES AND PRIVACY POLICY

We reserve the right to amend these CALIFORNIA EMPLOYEE CCPA DISCLOSURES AND PRIVACY POLICY at our discretion and at any time. When we make changes to these CALIFORNIA EMPLOYEE CCPA DISCLOSURES AND PRIVACY POLICY, we will notify you.

3. HOW TO CONTACT US

If you have any questions or comments about this policy, the ways in which we collect and use your personal information, your rights regarding such use, please contact our Chief Privacy Officer, Kate Vanderkolk.

Contacts
Privacy Support Phone:817-928-1500 x4342
Privacy Support Email:KVanderkolk@elevate.com
Postal Address:Elevate Attn: Privacy 4150 International Plaza Suite 300 Fort Worth, Texas 76109

Version 1.0 – Effective Date 1/1/2020QA