Mission Wealth Management, LP and the California Consumer Privacy Act (CCPA)

DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
 
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
 
Shine the Light Law: California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
 
Do Not Track Law: California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how a website operator responds to “Do Not Track” (“DNT”) browser settings. DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third party ad networks, social networks and analytic companies. We have not currently developed a response in line with DNT signals because a uniform technological standard has not yet been developed.
 
California Consumer Privacy Act: Under the California Consumer Privacy Act of 2018, Cal. Civil Code § 1798.100 et seq. and its implementing regulations (the “CCPA”), California “residents” have certain rights in their “personal information” as set forth below.
 
Definitions
 
“Device” means any computer, tablet, mobile phone, or any other device capable of accessing the Site.
 
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, Device, or household. Anonymous, de-identified, or aggregate information is not Personal Information.
 
“Resident” means: (1) every individual who is in the State of California for other than a temporary or transitory purpose and (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.
 
“Non-resident” means all other individuals who do not fall under the definition of “resident” above.
 
“Sensitive Personal Information” means personal information that reveals (a) consumer’s Social Security or other state identification number; (b) a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) consumer’s geolocation; (d) consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, or text messages, unless the business is the intended recipient of the communication; and (f) consumer’s genetic data. In addition, “sensitive personal information” includes processing of biometric information for purposes of identifying a consumer; personal information collected and analyzed concerning a consumer’s health, and personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.
 
“Service Provider” means a for-profit legal entity to whom we disclose Personal Information for processing on our behalf for a “business purpose” (as defined in the CCPA) pursuant to a written contract.
 
“Special Categories Personal Information” includes, subject to certain exceptions, personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. The processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation shall be prohibited.
 
“Third-Party Business” means any third party unaffiliated with us to whom we disclose Personal Information for their own purposes.
 
*If you fall under the definition of "resident" described above, we must adhere to certain rights and obligations regarding your personal information. *
 
What Categories of Personal Information Do We Collect? 
 
We may collect, obtain or otherwise acquire the following types of Personal Information about you, and we may make and retain inferences drawn from such information. In the past twelve (12) months, we have collected the following categories of personal information:
 

Category 

Examples 

Collected 

 

 

A. Identifiers 

Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet 

Protocol address, email address and account name 

 

 

YES 

B. Personal information categories listed in the California Customer Records statute 

Name, signature, Social Security number, physical characteristics or description, address, contact information, passport number, driver’s license or state identification card number, insurance policy number, bank account number or any other financial information, education, employment and employment history  

 

YES 

C. Protected classification characteristics under California or federal law 

 

Gender and date of birth 

 

NO 

 

D. Commercial information 

Transaction information, purchase history, products or services purchased, obtained or considered, financial details, such as income or net worth, and payment information 

 

NO 

 

E. Biometric information 

 

Fingerprints and voiceprints 

 

NO 

F. Internet or other similar network activity  

Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements 

NO 

G. Geolocation data 

 

Device location 

NO 

H. Audio, electronic, visual, thermal, olfactory, or similar information 

Images and audio, video or call recordings created in connection with our business activities 

NO 

I. Professional or employment- related information 

Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply 

for a job with us 

NO 

J. Education Information 

Student records and directory information 

NO 

K. Inferences drawn from other personal information 

Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s 

preferences and characteristics 

NO 
 
Collection of Additional Personal Information
 
We may also collect other personal information outside of these categories, in instances where you interact with us in-person, online, or by phone or mail in the context of:
  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our Services and to respond to your inquiries.
How Do We Use and Share Your Personal Information?  
 
Mission Wealth collects and shares your personal information through:
  • Targeting cookies/Marketing cookies
  • Beacons/Pixels/Tags
More information about our data collection and sharing practices, as well as how you can exercise your rights under the CCPA, can be found in this privacy notice.
 
Will Your Information Be Shared with Anyone Else? 
 
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
 
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal data.
 
Mission Wealth has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:
  • Category B. Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history and financial information.
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHO WILL YOUR INFORMATION BE SHARED WITH?".
 
Mission Wealth has not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Mission Wealth will not sell personal information in the future belonging to website visitors, users and other consumers.
 
Your Rights with Respect to Your Personal Information 
 
Right to request deletion of the data - Request to delete
 
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.
 
California residents have the following rights:
  • the right to know whether we collect and use your personal information;
  • the right to know the categories of personal information that we collect;
  • the right to know the purposes for which the collected personal information is used;
  • the right to know whether we sell your personal information to third parties;
  • the right to know the categories of personal information that we sold or disclosed for a business purpose;
  • the right to know the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
  • the right to know the business or commercial purpose for collecting or selling personal information.
  • the right to request specific pieces of your Personal Information that we hold;
  • the right to opt out of the sale of your Personal Information;
  • the right to request that we correct inaccurate Personal Information we have about you;
  • the right to request that we limit the use and disclosure of sensitive Personal Information collected about you; and
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
 
If you would like to request notice of what Personal Information is sold or shared and to whom, please submit a written request to this email (bstark@nullmissionwealth.com) or regular mailing address provided at the bottom of this document.
 
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
 
We will not discriminate against you if you exercise your privacy rights.
 
Verification process
 
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts may require us to ask you to provide supplemental information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
 
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
 
How You Can Exercise Your Rights under the CCPA 
 
California residents, as well as authorized agents seeking to submit requests on behalf of California residents and parents or guardians seeking to submit requests on behalf of their minors who are residents of California, may exercise the rights described below by email bstark@nullmissionwealth.com or by calling us at 805-882-2360. If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
 
As described above, you have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and have verified your consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. 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 have 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.
  • 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.
If you opt out of the sale of your Personal Information, we may still share your Personal Information with third parties if those transfers are not sales, such as with our Affiliates or our Service Providers.
 
Our Response Procedures 
 
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. 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, if applicable.
 
For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
 
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 a cost estimate before completing your request.
 
How Can You Contact Us About This Notice?
 
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at bstark@nullmissionwealth.com, by phone at 1-805-690-3901, or contact us by post at:
 
Mission Wealth
Data Protection Officer
1111 Chapala St
Santa Barbara, CA 93101
United States
 
SK 39094 0001 11779184 v1