California Consumer Financial Privacy Notice Conta Ideal

California Consumer Financial Privacy Notice

Effective Date: March 29,, 2023

Last Updated Date: September 28, 2023

California Resident Notification
The California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), grants specific rights to California residents concerning their personal information. This California Privacy Notice (“Notice”) delineates these rights and provides the necessary disclosures mandated by the CCPA regarding Evolution Finance, Inc. (“Evolution Finance,” “Conta Ideal,” “we,” “us,” or “our”) and how we collect, utilize, and disclose the personal information of California residents.

For comprehensive information about our personal information handling practices, please refer to our Privacy Policy.

Scope and Exemptions under CCPA
This Notice applies to personal information of California residents that falls within the definition of “personal information” under the CCPA, to the extent that Evolution Finance processes such personal information in its capacity as a “business” under the CCPA. However, this Notice does not apply to information that is exempt from or not subject to the requirements of the CCPA. In certain cases, we may issue a distinct notice to California residents in accordance with the CCPA, and in such instances, that notice will take precedence over this one.

Categories of Personal Information We Collect
Currently, and in the 12 months preceding the Last Updated Date of this Notice, we have collected and are collecting the following categories of personal information:

  1. Identifiers (e.g., name, postal address, online identifier, Internet Protocol address, email address, Social Security number, government-issued ID number, driver’s license number)
  2. Unique personal identifiers (e.g., device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or similar technologies; other forms of persistent or probabilistic identifiers that can identify a specific consumer or device)
  3. Telephone number
  4. Physical characteristics or description (e.g., height and weight)
  5. Medical information (e.g., height, weight, smoking habits, medical conditions, and psychological conditions)
  6. Internet or other electronic network activity information (e.g., browsing history; search history; and information regarding a consumer’s interaction with a website, application, or advertisement)
  7. Geolocation data
  8. Commercial information (e.g., billing, payment, and transaction information; information about your financial products; and your credit report)
  9. Education information
  10. Professional or employment-related information, including employment history (e.g., education data and income)
  11. Characteristics of protected classifications under California or federal law (e.g., gender and age, specifically 40 and older)
  12. Inferences drawn from personal information to create a consumer profile (e.g., information about financial products and services that may interest you)
  13. Sensitive Personal Information: Personal information that reveals a consumer’s Social Security number, driver’s license, state identification card, passport number, account log-in and password (for Conta Ideal), and the contents of a consumer’s messages on Conta Ideal.

Additionally, we collect public content that you may provide, such as reviews, comments, questions and answers, posts, followers, groups, businesses, professionals you have interacted with, topics and users you follow, as well as any other information displayed on your Conta Ideal profile page.

We collect personal information directly from California residents, credit bureaus, third-party platforms used by consumers to log in to our Services (e.g., Facebook), publicly available sources, other users, partners providing offers for financial products and services, your browser or device, advertising networks, data analytics providers, government entities, and data brokers. Please note that we do not collect all categories of personal information from all users or from all sources.

Purposes for Collecting Personal Information
We currently collect and have collected the aforementioned categories of personal information for the following business or commercial purposes:

  1. Auditing related to ad impressions, verifying ad quality, and ensuring compliance with specifications and standards
  2. Enhancing security and integrity as necessary and proportionate to protect your personal information
  3. Debugging to identify and correct errors impacting intended functionality
  4. Short-term, transient use, including non-personalized advertising during your current interaction with us
  5. Providing services, including account maintenance, customer service, order and transaction processing, and customer information verification
  6. Delivering advertising and marketing services (except for cross-context behavioral advertising)
  7. Conducting internal research for technological development and demonstration
  8. Improving, upgrading, or enhancing our service
  9. Advancing our commercial or economic interests

Sale, Sharing, and Disclosure of Personal Information
The following table illustrates the categories of personal information that we sold or shared with third parties in the 12 months preceding the Last Updated Date of this Notice, along with the categories of third parties to whom we sold or shared personal information:

Category of Personal Information Categories of Third Parties
Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology); online identifiers, Internet Protocol addresses; internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application, or advertisement) Advertising networks; data analytics providers; partners providing offers for financial products/services
As elaborated further below, we do not engage in the conventional sale of information for monetary compensation. Nevertheless, our disclosure of personal information to third parties for the purpose of displaying advertisements and providing analytics services for our Site may be deemed a “sale” or “sharing” under California law.

The following table specifies the categories of personal information that we disclosed for a business purpose in the 12 months preceding the Last Updated Date of this Notice, along with the categories of recipients to whom we disclosed personal information.

Category of Personal Information Categories of Recipients
Identifiers (e.g., name, postal address, email address, Social Security number, government-issued ID number); commercial information about your financial products; inferences drawn from personal information to create a profile about a consumer (e.g., information about financial products and services that may interest you); telephone number; unique personal identifiers (device identifier; other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device) Credit bureaus; partners providing offers for financial products/services
Commercial information (billing, payment, and transaction information) Payment processors
Commercial information (credit report) Partners providing offers for financial products/services

We disclosed personal information for the aforementioned business purposes. We do not knowingly collect, sell, or share the personal information of consumers under 16 years of age. We currently do not use sensitive personal information for purposes other than those permitted by the CCPA and its regulations.

Retention of Personal Information
We retain your personal information for the duration required to fulfill the purposes for which we collected it, including providing requested services, and for the purpose of complying with applicable legal, accounting, contractual, or reporting obligations.

CCPA Rights
The CCPA bestows upon California residents the following rights. These rights are not absolute and are subject to certain exemptions, which may lead to the denial of your requests in accordance with the law:

  1. The right to know what personal information we have collected about you, encompassing the categories of personal information, sources from which we collected personal information, the business or commercial purpose for collecting, selling, or sharing personal information (if applicable), the categories of third parties to whom we disclose personal information (if applicable), and the specific pieces of personal information collected about you.
  2. The right to request the deletion of