Privacy Policy

This California Consumer Privacy Act Disclosure (“CCPA Disclosure”) explains how Splitero collects, uses, and discloses personal information subject to the California Consumer Privacy Act (“CCPA”). It also describes the privacy rights of California residents under the CCPA and how they can exercise those rights.

This CCPA Disclosure applies solely to California residents and supplements any other privacy policies or notices applicable to the Capital One services that you visit or use.

• What Personal Information Is Covered by the CCPA?

  Under the CCPA, “personal information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.The CCPA does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, and certain other state or federal privacy laws. This CCPA Disclosure also does not apply to information that we collect in connection with providing products or services to other businesses or when receiving products or services from our suppliers.

  What Information Is Collected?

  • We collect and have collected, used, and disclosed, in the past twelve (12) months, the following categories of Personal Information about California residents:
  • Identifiers such as full name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, account title, Social Security number, driver’s license number, passport number, or other similar identifiers;
  • Personal Information as defined in the California safeguards law such as driver’s license or state identification card number, bank account number, debit card number, or any other financial information;
  • Protected classification characteristics under California or federal law such as age, citizenship, physical or mental disability, veteran or military status;
  • Commercial information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
  • Internet or other electronic network activity or information such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement; Geolocation data such as physical location or movements;
  • Sensory data such as audio, electronic, or similar information;
  • Professional or employment-related information; and
  • Inferences drawn from other personal information which may include a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

  
  

  We collect the above categories of Personal Information from the following sources:

  • From California residents or authorized agents and parties (e.g., from documents that you provide to us related to the services for which you engage us or through information we collect from you including your employer, in the course of providing services to you);
  • Directly and indirectly from your activity on our digital properties (e.g., from submissions through our website portal or website details we collect automatically);
  • From third parties (e.g., credit bureaus and consumer data resellers) that interact with us in connection with services and activities we perform; and
  • From our affiliates.

  
  

  We collect and have collected in the past twelve (12) months the above categories of Personal Information for one or more of the following business or commercial purposes:

  • To fulfill or meet the reason for which the information was provided or related products and services. If you provide your personal information to purchase a product or service, we will use that information to process your request;
  • To provide, support, and develop our websites, products, and services;
  • To create, maintain, customize, and secure your account with us;
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud;
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our response;
  • To personalize your website experience and to deliver relevant content and product and service offerings, including targeted offers and ads through our websites, third-party sites, and via email or text message (with your consent, where required by law);
  • To help maintain the safety, security, and integrity of our business websites, products and services, databases and other technology assets;
  • For testing, research, analysis, and product development, including to develop and improve our websites, products, and services;
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; and
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

  
  

• Sharing of Personal Information

  We disclose the above categories of your Personal Information to third parties for business purposes or as required or permitted by law including with our affiliates and subsidiaries, service providers, third parties to whom you authorize us, directly or indirectly, to disclose your personal; information in connection with products or services we provide to you and government or regulatory authorities, as required by law.




• Sale of Personal Information

  In the preceding twelve (12) months, we have not sold or otherwise disclosed to a third party for monetary or other valuable consideration any Personal Information subject to the CCPA.




• Your Rights Under the CCPA

  
  As a California resident, you have the right to request that we disclose certain information about our collection and use of your personal information over the past twelve (12) months including:

  • The categories of Personal Information we have collected about you;
  • The categories of sources from which we have collected Personal Information about you;
  • The business or commercial purpose for collecting that Personal Information;
  • The business purpose for disclosing that Personal Information to third parties;
  • The categories of third parties with whom we have shared or share that Personal Information;
  • The categories of Personal Information we have disclosed or shared with a third party for a business purpose; and
  • The specific pieces of Personal Information we have collected about you.

  
  

• Deletion Request Rights

  California law gives you the right to request deletion of your Personal Information. We limit the Personal Information that we collect from you and only collect Personal Information from you for business or commercial purposes. Splitero is providing the following methods to request deletion to comply with the CCPA. However, please keep in mind that Splitero is not required to honor your request for deletion if the Personal Information is needed for a business purpose.




• Exercising your Rights

  
  If you are a California resident, you can submit a request to us by:

  • Emailing us: [email protected]
  • Calling us: 888.365.3372

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

  You may only make a verifiable consumer request twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the California resident about whom we collected personal information or an authorized representative of such a resident.
  • 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. Our practices with regard to verifying a request will vary depending on the request and the information we have on the person making the request.




• Response Time and Method

  We will respond to your verifiable request within ten (10) days of receipt. We will provide access to personal information within forty-five (45) days of receiving your request. If we require more time (up to 90 days), we will notify you in writing and inform you of the reason. We will deliver our written response by mail or electronically (provided we can do so securely) at your direction. The response we provide will also explain the reasons we cannot comply with a request, if applicable. Further, we will not provide Personal Information, such as a Social Security number or any other specific pieces of Personal Information, if the disclosure could result in unauthorized access, causing fraud or other security risks. We will only use the personal information you provide to verify your identity or identity of the individual on whose behalf you are making the request.




• Non-discrimination

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




• Information for Parents or Guardians

  We do not knowingly collect or maintain information about children under the age of  16 unless that information is provided by a parent, legal guardian, or authorized adult.




• Changes to this Privacy Notice

  We reserve the right to update this Privacy Notice at any time to reflect changes in our business, legal or regulatory obligations. Any changes will be immediately effective upon the posting of the updated Privacy Notice.