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  • California Residents:

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    This Privacy Notice and Disclosure for California Residents applies solely to those who reside in the State of California (“consumers” or “you”).

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    The purpose of this privacy notice and disclosure is to inform California residents, at or before the time of collection of personal information and to inform you as part of our privacy policies:

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    • • Your “Right to Know” about personal information collected, used, and disclosed including:
    • - The categories of personal information we collect from you and the purpose for its collection,
    • - How we use those categories of personal information, and
    • - How we share the personal information you entrust to
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    • • That we do not sell your personal information.
    • • Your “Right to Delete” personal
    • • How to submit a verified consumer “Request to Know” or “Request to Delete.”
    • • How to use an authorized agent to submit a verified consumer
    • • Your “Right to Non-Discrimination” for the exercise of a privacy
    • • Privacy Notice and Disclosure for California Residents
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  •  Your Right to Know

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  • You have the right to request that Spring EQ, LLC (“Spring EQ”, “Company” or “we”) disclose what personal information it collects, uses, discloses, and sells. You can do this through a verified consumer request. That process is described below in the section, “Submitting a Verified Consumer Request.”

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  • We collect personal information, which means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). The following table includes disclosures of the personal information we collect from consumers and the purposes for which it is collected and used, as well as lists of categories of consumers’ personal information we have collected about consumers in the past 12 months, the categories of sources from which it was collected and categories of third parties with whom we share the personal information.

     

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  • Please note that Personal Information does not include:

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  • Publicly available information or lawfully obtained, truthful information that is a matter of public concern.
    • Deidentified or aggregated consumer information.

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  • Certain information is excluded from the scope of certain requirements of the California Consumer Privacy Act. This includes, without limitation:


  • • Personal information collected, processed, sold or disclosed subject to industry-specific privacy laws, including the federal Fair Credit Reporting Act (FCRA), the federal Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act.

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  • We will not collect additional categories of personal information or use the personal information for any other undisclosed purpose without providing you notice.

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  • Your Right to Opt-Out


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  • We do not sell the personal information of anyone, including minors under 16 years of age, without affirmative authorization.
 


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  • Your Right to Request Deletion of Your Personal Information


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  • You have the right to request that the Company delete any of your personal information collected or maintained by the Company, subject to certain exceptions. You can do this through a verified consumer request. That process is described below in the section, “Submitting a Verified Consumer Request."

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We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:


  • • 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.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such
    • Debug products to identify and repair errors that impair existing intended functionality.
    • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    • 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.
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.



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  • Submitting a Verified Consumer Request


  • California residents have the right to submit verified consumer requests to know or delete information. If you are a California resident, you can make a Request to Know or Request to Delete by:


  • • Contacting us at (888) 978-9978

  • Emailing your request to cxo@springeq.com

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  • You may only make a verifiable consumer request to know information twice within a 12-month period. 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 that the personal information relates to you. We may request additional information to verify your identity prior to fulfilling your request. Once we receive your verifiable request, we will send you an acknowledgement letter within 10 days which will describe our verification process. We will respond to your request within 45 days, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted.


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  • 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.

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Please note we are unable to disclose or provide you with your Social Security Number, Driver’s License Number, or other government issued identification number, financial account number, any health insurance or medical identification number, an account password, or security questions and answers.


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  • Using an Authorized Agent to Submit a Request
 


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  • Only you, a person registered with the California Secretary of State, or a person 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. If you use an authorized agent, you may provide a power of attorney executed pursuant to California Probate Code sections 4000 to 4465. If a power of attorney that meets those provisions is not submitted, you will be required to verify your identity directly by submitting a verified consumer request according to the procedures in the section “Submitting a Verified Consumer Request.” If anyone purporting to be an authorized agent for a consumer contacts us, we will require proof that the authorized agent has been authorized to act on the consumer’s behalf.
 


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  • Your Right to Non-Discrimination for the Exercise of a Privacy Right


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  • We will not discriminate against you for exercising any of your CCPA rights. We will not:
    • Deny you goods or
    • 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

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

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  • However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
 


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  • Changes to Our Privacy Notice


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  • The Company reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the
notice’s effective date. Your continued use of our Website following the posting of changes constitutes
your acceptance of such changes.
 


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  • Contact for More Information


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  • If you have any questions or comments about this notice, the ways in which the Company collects and uses your 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:


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  • Phone: (888) 978-9978
 


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  • Spring EQ, LLC


  • 2929 Arch Street, Suite 500

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Philadelphia, PA 19104


  • Attn: Customer Experience Office


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Last Update: August 4, 2021