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:

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:

1.2. How We Obtain Your Personal 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 in an employment application, or documents you provide to verify your identity.

Directly and indirectly from you based on activity on our website or network.

For example, from internet browsing or network usage details collected automatically.

From vendors or third-parties that interact with us in connection with your employment position.

For example, employment agencies, credit reporting agencies from which we check your credit in connection with a submitted employment application, or other vendors that provide background search results.

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:

1.4. 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:

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

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, employment 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.

No

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.

Yes

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, Your activity on our site or network; or from service providers and third-parties

1-7

Service providers and third-parties

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.

Yes

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.

Yes

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.

Version 1.0 – Effective Date 1/1/2020