This Privacy Notice for California Consumers (“Notice”), provided by Patriot 1 Advantage (“Patriot 1 Advantage,” “Company,” “we,” or “our”), supplements, and is expressly made part of, the information contained in the Patriot 1 Advantage Online Privacy Policy and applies solely to those who are consumers (“you” or “your”) as defined in Section 1798.140(g) of the California Consumer Privacy Act of 2018 (“CCPA”). We adopt this Notice in compliance with the CCPA, and any terms defined in the CCPA have the same meaning when used in this Notice.
Patriot 1 Advantage collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). As a consumer, you have certain rights regarding your personal information as defined in the CCPA. This Notice provides you with information on how Patriot 1 Advantage collects, uses, and shares personal information. It also outlines the rights you have regarding personal information that we collect from you and describes how you can exercise those rights.
Collection and Use of Personal Information
Patriot 1 Advantage recognizes the eleven (11) broad categories of personal information referenced in the CCPA that a business may collect about a consumer. In particular, Patriot 1 Advantage has collected the following categories of personal information from consumers within the last twelve (12) months:
Category
Examples
Collected
A. Identifiers.
A genuine name, pseudonym, residential address, distinct personal marker, digital identifier, IP address, email address, account designation, SSN, driver’s license ID, passport ID, or analogous identifying details.
YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A title, autograph, SSN, physical attributes or portrayal, location, phone number, passport ID, driver’s license or state ID card ID, insurance policy ID, educational background, job details, work history, bank account ID, credit card ID, debit card ID, or any financial data, medical details, or health insurance particulars. Some details in this grouping may coincide with other classifications.
YES
C. Protected classification characteristics under California or federal law.
Age (over 40 years), ethnicity, hue, lineage, country of origin, citizenship status, faith or belief, marital situation, health status, physical or mental incapacity, gender (including identity, expression, pregnancy or childbirth-related conditions), sexual orientation, veteran or military standing, genetic data (including familial genetic traits).
YES
D. Commercial information.
Records of personal property, purchased products or services, and considered items, along with other purchasing or consuming behaviors, form a crucial aspect of consumer data. These records encompass various transactions, including purchases, inquiries, and browsing activities. Analyzing this data allows businesses to understand consumer preferences, tailor marketing strategies, and enhance customer experiences. Additionally, it facilitates the development of personalized recommendations and promotions, fostering stronger customer relationships and driving business growth.
YES
E. Biometric information.
Genetic, physiological, behavioral, and biological traits, along with activity patterns, contribute to the extraction of identifiers or identifying information. These include fingerprints, faceprints, and voiceprints, as well as iris or retina scans. Moreover, keystroke dynamics, gait analysis, and other physical patterns are utilized for identification purposes. Additionally, data related to sleep, health, or exercise behaviors are considered within this category, reflecting a broad spectrum of personal characteristics and activities.
NO
F. Internet or other similar network activity.
The browsing history, search history, and details of a consumer's interactions with websites, applications, or advertisements are encompassed within this category. It includes information about the websites visited, searches conducted, and interactions with online content, such as clicks on advertisements or engagement with specific features of websites or applications.
YES
G. Geolocation Data
The physical location or movements of an individual are covered under this category. It refers to data related to the geographic location of a person or their movements over time, such as GPS coordinates, tracking information, or records of places visited.
NO
H. Sensory Data
Audio, electronic, visual, thermal, olfactory, or similar information pertains to data captured through various sensory modalities, including sound, electronic signals, images, heat signatures, smells, or comparable types of data.
NO
I. Professional or employment-related information.
Current or past job history or performance evaluations.
NO
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 a party acting on its behalf, encompass various aspects of a student's academic journey. This includes information such as grades, transcripts, class lists, student schedules, student identification codes, student financial details, and records of disciplinary actions.
NO
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
YES
As a financial institution under the Gramm-Leach-Bliley Act (GLBA), Patriot 1 Advantage conducts activities of a financial nature. Although the CCPA does not provide exemptions for financial institutions, Section 1798.145(e) of the CCPA specifically exempts personal information collected by financial institutions under the GLBA. Personal information, in this context, excludes publicly available information from government records, de-identified or aggregated consumer data, or information excluded from the CCPA's scope, such as data collected under the GLBA. The categories of personal information listed above have been obtained from the following sources:
The categories of personal information listed above have been obtained directly from you. This includes information provided through forms you complete or products and services you purchase.
We also obtain some categories of personal information indirectly from you. For instance, we gather information during the provision of our services to you or by observing your interactions on our website.
Additionally, we receive certain categories of personal information from third-party business partners, including but not limited to social media platforms, advertising networks, and analytics providers.
Patriot 1 Advantage may utilize this information to:
Fulfill your requests for information, products, or services from us.
Complete the purpose for which you provided the information.
Create, maintain, customize, and secure your account with us.
Tailor your website experience and provide content, products, and services tailored to your interests, including personalized offers and advertisements on our site, third-party sites, and through email or text messages (where applicable legal consent is obtained).
Promote and market products and services to you from affiliated and non-affiliated entities, including sending promotional materials, targeted advertisements, and offering relevant deals (with necessary legal consent).
Ensure the safety, security, and integrity of our website, products, services, databases, technological assets, and overall business operations.
Handle your requests, purchases, transactions, and payments efficiently and securely.
Offer assistance and address your inquiries promptly, including investigating and resolving any concerns you may have, while continuously monitoring and enhancing our customer support services.
Conduct testing, research, and analysis to enhance our website, products, and services, fostering continuous improvement and innovation.
Obtain data from our third-party business partners, including social media platforms, advertising networks, and analytics providers, to enrich our understanding of consumer preferences and behaviors.
Comply with law enforcement requests and obligations under applicable laws, court orders, or governmental regulations.
As explained to you during the collection of your personal information or as outlined in the CCPA.
Patriot 1 Advantage may share your personal information with third-party service providers for business purposes. We disclose your personal information to the following categories of third parties for such purposes:
Affiliates.
Service providers – When Patriot 1 Advantage shares with a Service Provider it enters into a contractual arrangement that describes the business purpose and requires the provider to both: (A) keep that personal information confidential; and (B) not use it for any purpose except performing the obligations under the contract.
Financial Institutions – our sharing of your personal information with these entities is limited only to when you affirmatively direct us to share your personal information with these companies.
In the past twelve (12) months, Patriot 1 Advantage has disclosed the following categories of personal information for business purposes:
Category A: Identifying information.
Category B: Personal information from California customer records.
Category C: Personal information related to protected classification characteristics under California or federal law.
Category D: Personal information related to commercial transactions and purchasing behavior.
Category K: Characteristics and trends inferred from analysis of other personal information.
Sale of Personal Information
The CCPA similarly requires Patriot 1 Advantage to provide you with a statement on its personal information sales. The definition of “Sale” under the CCPA is very broad. Out of an abundance of caution, we are providing you with the below notice. In the preceding 12 months, we may have sold the below categories of information:
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 K: Inferences drawn from other personal information
We sell these categories of personal information for commercial purposes to the following categories of third parties:
Financial Institutions –including, for example, Debt Settlement Service Providers and Lenders.
Business partners and third parties – We may also share Information with business partners and third parties (e.g., other companies, retailers, research organizations, advertisers, ad agencies, advertising networks and platforms, social networks, participatory databases, publishers, and non-profit organizations) that may want to market products or services to you.
Please note that once we sell your personal information with another company, the information received by the other company is controlled by that company and becomes subject to the other company’s privacy practices.
RIGHT TO OPT-OUT OF SALE OF PERSONAL INFORMATION
TO EXERCISE THE ACCESS, DATA PORTABILITY, AND DELETION RIGHTS DESCRIBED ABOVE, PLEASE SUBMIT A VERIFIABLE CONSUMER REQUEST TO REGIONAL FUNDS NETWORK BY:
FILLING OUT THE CALIFORNIA CONSUMER REQUEST FORM AVAILABLE AT BY CLICKING HERE.
Notice Regarding Your Rights
YOU HAVE THE RIGHT TO REQUEST THAT PATRIOT 1 ADVANTAGE DISCLOSE WHAT PERSONAL INFORMATION WE COLLECT, USE, AND DISCLOSE. IF WE RECEIVE AND CONFIRM YOUR CONSUMER REQUEST AS VERIFIABLE AND NO EXCEPTION APPLIES, WE WILL PROVIDE YOU WITH:
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 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.
If we sold or disclosed your personal information for a business purpose, two lists disclosing
Sales, identifying the personal information categories that each category of recipient purchased. Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. DELETION REQUEST RIGHTS
Subject to certain exceptions, you have the right to request that we delete any of your personal information that we collected from you and retained. If we receive and confirm your consumer request as verifiable, unless an exception applies, we will delete (and direct our service providers to delete) your personal information from our records.
The CCPA provides a number of reasons why a deletion request may be denied. 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
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.
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.
RIGHT TO OPT-OUT OF SALE OF PERSONAL INFORMATIONYou have the right to request that Patriot 1 Advantage no longer sell your personal information. To exercise that right, please click here: Do Not Sell My Personal Information or call us toll-free during business hours EXERCISING ACCESS, DATA PORTABILITY, AND DELETION RIGHTSTo exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to
Patriot 1 Advantage by Filling out the California Consumer Request form available by clicking here. Only you or someone registered with the California Secretary of State and legally authorized to act on your behalf may make a verifiable consumer request related to your personal information. 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 Patriot 1 Advantage to verify, to a reasonable degree of certainty, that you are the person about whom
Patriot 1 Advantage collected personal information (or your authorized representative), which may include multi-factor authentication of identifying information provided by you. Such authentication may be conducted and verified independently or in combination with a comparison of personal information already maintained by Patriot 1 Advantage, if any; andDescribe your request with sufficient detail that allows Patriot 1 Advantage 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 that the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us, but we must also be able to confirm the personal information relates to you. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
RESPONSE TIMING AND FORMATPatriot 1 Advantage endeavors to respond to a verifiable consumer request within forty-five (45) days of receiving it. If Patriot 1 Advantage requires additional time to process your request, up to a maximum total of ninety (90) days from the date the request is received, we will notify you of this and inform you of the reason for requiring the additional time.
If you have an online account with us, we will deliver our written response to your online 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 or have denied a request, if applicable.
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-DISCRIMINATIONPatriot 1 Advantage will not discriminate against you for exercising any of your CCPA rights as described above. Unless permitted by the CCPA, Patriot 1 Advantage will not:
Deny you goods or services.
Describe your request with sufficient detail that allows Patriot 1 Advantage to properly understand, evaluate, and respond to it. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. HOW DO WE RESPOND TO WEB BROWSER “DO NOT TRACK” SIGNALS OR OTHER MECHANISMS THAT PROVIDE CONSUMERS THE ABILITY TO EXERCISE CHOICE REGARDING THE COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION ABOUT AN INDIVIDUAL CONSUMER’S ONLINE ACTIVITIES OVER TIME AND ACROSS THIRD-PARTY WEBSITES OR ONLINE SERVICES? We currently do not respond to DNT signals in browsers because we do not track individual users across the web.
MAY OTHER PARTIES COLLECT PERSONALLY IDENTIFIABLE INFORMATION ABOUT AN INDIVIDUAL CONSUMER’S ONLINE ACTIVITIES OVER TIME AND ACROSS DIFFERENT WEBSITES WHEN THEY VISIT WWW.patriot-1-advantage.COM ? No.
OTHER CALIFORNIA PRIVACY RIGHTSCalifornia’s “Shine the Light” law (Civil Code Section § 1798.83) permits certain individuals that are California residents to request information regarding our disclosure of personal information to third parties for their direct marketing purposes.
Patriot 1 Advantage LLC
Phone: 888-423-8454
Please print and retain a copy of this California Privacy Notice for your records. For a PDF version of this Privacy Notice For California Consumers suitable for printing as a separate document, please click below. You must have PDF software such as Adobe Acrobat Reader in order to view and print PDF documents. If you need Acrobat Reader, you can download it from Adobe for free by clicking here.
