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Privacy Notice for California Residents

LeadPoint, Inc. dba SecureRights
Last Update Date: December 2022

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS (“Notice”) supplements the information contained in the Privacy Policy found on SecureRights.org, Introlend.com, LeadPoint.com, AvenuTech.com, the Introlend App and the HomeKick App (collectively, the “Site,” “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you” or “your”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act of 2020 (“CPRA”) and other applicable California privacy laws. Any terms defined in the CCPA have the same meaning when used in this Notice. This Notice contains disclosures required by the CCPA and applies to “personal information” under the CCPA.

Information We Collect

We collect personal information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). Specifically, we collect the categories of personal information about California consumers identified in the chart below and use and disclose to third parties this information for business or commercial purposes. As is commonly done by online companies, we may allow certain third parties, including non-affiliated business partners, advertising networks, analytics providers, and other advertising providers, to directly collect information about your online activities on the Site and across your browsers and devices using cookies, web beacons, mobile advertising identifiers and other technologies. These third parties may use this information to display online advertisements tailored to your interests and preferences across your browsers and devices, to conduct ad campaign measurement and Site analytics, to detect, prevent and report fraud, or to carry out their own business and commercial purposes. The collection of information by some of these third parties may constitute a “sale” of personal information, as defined under the CCPA.

We have collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples Collected
A. Identifiers A real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. YES
B. Personal information
categories (Cal. Civ. Code § 1798.80(e))		 A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state ID number, insurance policy number, education, employment, bank account number, credit/debit card number, or health information. May overlap with other categories. YES
C. Protected classification
characteristics		 Age (40+), race, color, ancestry, national origin, religion, marital status, medical condition, disability, sex/gender, pregnancy, sexual orientation, veteran/military status, genetic info. YES
D. Commercial information Records of property, products or services purchased, obtained or considered, or purchasing/consuming tendencies. YES
E. Biometric information Fingerprints, faceprints, voiceprints, iris/retina scans, keystroke, gait, or sleep, health or exercise data. NO
F. Internet or other similar network activity Browsing history, search history, consumer interaction with website, application or advertisement. YES
G. Geolocation data Physical location or movements. NO
H. Sensory data Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related info Current or past job history or performance evaluations. YES
J. Non-public education info
(FERPA – 20 U.S.C. § 1232g, 34 C.F.R. Part 99)		 Student records maintained by an educational institution, such as grades, class lists, schedules, ID codes, financial info, disciplinary records. NO
K. Inferences drawn from other personal info Profile reflecting preferences, characteristics, psychological trends, behavior, attitudes, intelligence, abilities, and aptitudes. YES

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, 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 (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
  • Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
  • Directly and indirectly from activity on our websites (www.leadpoint.com, www.introlend.com, www.myavenu.com, www.avenutech.com, www.securerights,com) and our partner websites (as identified by the SecureRights.org logo). For example, from submissions through our website portal or website usage details collected automatically.
  • From third-parties that interact with us in connection with the services we perform. For example, from credit bureaus such as TransUnion or Experian when you request to view your credit report.

Use of Personal Information

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

  • To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to help you review mortgage quotes, we will use that information to deliver quotes to you from our participating lenders.
  • To provide you with information, products or services that you request from us.
  • To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  • To improve our website and present its contents to you.
  • For marketing analytics, testing, research, analysis and product development.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A:        Identifiers.

Category B:        California Customer Records personal information categories.

Category C:        Protected classification characteristics under California or federal law.

Category D:        Commercial information.

Category I:        Professional or employment-related information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates.
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have sold personal information.

Why We Collect, Use and Share Personal Information

We use and disclose the personal information we collect for our commercial and business purposes.

Commercial purposes include, without limitation: marketing, advertising, authentication, identity resolution, fraud prevention, fulfillment services, and fulfilling the requests of our customers.

Business purposes, as identified in the CCPA, include: audits and related activities; legal compliance; detecting and protecting against security incidents, fraud, and illegal activity; debugging services and systems; administrative and support services such as processing orders and payments and analytics; internal research and operations; activities to maintain and improve our Services; and other one-time uses.

We disclose the categories of personal information designated above to the following categories of third parties: service providers, lending partners, financial service aggregators, government entities, advertising networks, internet service providers, data analytics providers, operating system providers, and social networks.

 

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Summary

Right to Request: For certain personal information categories, you have the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties.

Right to Know: You have the right to know the categories and specific pieces of personal information we collect, use, disclose and, if applicable, sell about you; the categories of sources from which we collected your personal information; our purposes for collecting or, if applicable, selling your personal information; the categories of your personal information that we have disclosed for a business purpose or, if applicable, sold; and the categories of third parties to whom we have disclosed for a business purpose or, if applicable, sold personal information.

Right to Request Deletion: You have the right to request that we delete the personal information we have collected from you.

Right to Opt Out: You have the right to opt out of our sale of your personal information.

Nondiscrimination: You have the right not to receive discriminatory treatment for the exercise of the privacy rights provided by the CCPA.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal, regulatory or contractual obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing your request to ccpa_requests@avenutech.com.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We do not sell the personal information of consumers we know to be under the age of 16 years.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

 

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (310) 209-8600
Website: www.leadpoint.com
Email: privacy@securerights.org
LeadPoint, Inc., dba SecureRights
Attn: Noah Staitman, COO
5717 Legacy Drive, Suite 250
Plano, TX 75024