California Privacy Notice (CCPA / CPRA)

1. Categories of Personal Information Collected

Depending on how you interact with our website, services, and marketing channels, we may collect the following categories of personal information as defined under CCPA/CPRA:

• Identifiers such as name, email address, phone number, IP address, online identifiers, and device identifiers
• Personal records such as contact information and household details
• Commercial information such as services considered or requested
• Internet or network activity information such as browsing interactions on our website
• Approximate geolocation data derived from IP address
• Professional or employment-related information such as employment status or income ranges
• Inferences drawn from the above data to personalize content or offers

We do not require Social Security Numbers or ITINs for general use of our services unless explicitly disclosed on a specific form for a particular partner product. If collected, such data is treated as Sensitive Personal Information.

2. Sources of Personal Information

We collect personal information from the following sources:

• Directly from you
• Automatically through your browser or device
• From service providers and analytics vendors
• From advertising and measurement partners
• From affiliates within our corporate group where permitted
• From partners to whom you request to be connected for products or services

3. Purposes for Collection, Use, and Disclosure

We collect, use, and disclose personal information for business and commercial purposes including:

• Providing and operating our website and services
• Matching users with third-party offers and partners
• Communicating with users
• Analytics, attribution, and reporting
• Marketing and advertising (subject to applicable opt-out rights)
• Fraud prevention and security
• Legal compliance
• Enforcing our Terms & Conditions
• Improving our products and user experience

4. Sensitive Personal Information (SPI)

We collect and use Sensitive Personal Information only to the extent reasonably necessary to:

• Provide requested services
• Ensure security and integrity
• Comply with legal obligations
• Perform services on our behalf

Where required by CPRA, California residents may have the right to limit certain uses of Sensitive Personal Information.

5. Sale and Sharing of Personal Information

We may disclose certain personal information in ways that may be considered a "sale" or "sharing" under CCPA/CPRA, particularly in connection with advertising and analytics technologies that support cross-context behavioral advertising.

California residents have the right to opt out of the sale or sharing of personal information at any time by sending us an email to compliance@clearcreditpath.com requesting to Do Not Sell or Share.

We honor legally required opt-out preference signals, including Global Privacy Control (GPC), where applicable.

6. Retention of Personal Information

We retain personal information only for as long as reasonably necessary to fulfill the purposes described in this Notice, unless a longer retention period is required or permitted by law. Retention periods depend on:

• The nature of the data
• Legal obligations
• Fraud prevention needs
• Operational requirements

7. Consumer Rights Under CCPA/CPRA

California residents have the following rights:

• Right to Access: Request access to personal information we collect about you
• Right to Delete: Request deletion or correction of certain personal information
• Right to Opt-Out: Opt out of the sale or sharing of personal information
• Right to Limit: Limit certain uses of Sensitive Personal Information
• Right to Non-Discrimination: Not be discriminated against for exercising privacy rights

8. Exercising Your California Privacy Rights

You may submit a California privacy rights request by contacting us at compliance@clearcreditpath.com.

We will verify your identity before responding to certain requests, using information reasonably necessary to confirm your identity. Authorized agents may submit requests on your behalf with proper authorization.

9. Children's Information

Our services are not directed to individuals under the age of 18. We do not knowingly sell or share the personal information of consumers under 16 years of age.

10. Changes to This Notice

We may update this California Privacy Notice from time to time. Any changes will be reflected by updating the "Last Updated" date above and, where required by law, we will provide additional notice.

11. Contact Information

For questions or to exercise your California privacy rights, contact: