CLOUDVIRGA -

California Disclosures and Privacy Policy (“California Privacy Policy”

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The State of California requires that we provide privacy information for individuals who reside in California. If you do not reside in California, the provisions of this California Privacy Policy will not apply to you.

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For California residents, here is a summary of what you will learn from this California Privacy Policy:

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• 1. Personal Information We Collect
•     1.1. Personal information does not include
•     1.2. Categories of personal information collected
•     1.3. How we obtain your personal information
•     1.4. How we use your personal information
•     1.5. How long we retain your personal information
•     1.6. Who we disclose your personal information with
•     1.7. Sale of personal information
•     1.8. Sharing of personal information
• 2. Your rights under the CCPA
•     2.1. Right to Know
•     2.2. Right to Delete
•     2.3. Right to Correct
•     2.4. Right to Limit Use of Sensitive Personal Information
•     2.5. Right to Opt-Out and How to Submit an Opt-Out Request
•     2.6. Right to Non-Discrimination
• 3. Submitting a Request to Know, Request to Delete or Request to Correct
•     3.1. How to submit a request
•     3.2. Authorized agents
•     3.3. Response timing and delivery method
• 4. Social Media
• 5. Changes to California Privacy Policy
• 6. How to contact us
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Below is the legal information we are required to share:

The California Privacy Policy supplements the information contained in the general Privacy Policy and Terms of Service of CLOUDVIRGA, Inc., and all of its operating affiliates and subsidiaries, the website www.cloudvirga.com, and CLOUDVIRGA platform and mobile applications (collectively, “CLOUDVIRGA,” “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this California Privacy Policy to comply with California privacy laws. The California Consumer Privacy Act and the California Privacy Rights Act are collectively referred to as

“CCPA. ” Any terms defined in the CCPA have the same meaning when used in this California Privacy Policy.

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1. PERSONAL INFORMATION WE COLLECT

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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, device, or household (“personal information”).

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1.1. Personal information does not include:

1. Publicly available information from government records
2. De-identified or aggregated consumer information
3. Information excluded from the CCPA, such as personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), and California Financial Information Privacy Act (CalFIPA).

AS A COURTESY, THE FOLLOWING DISCLOSURES INCLUDE INFORMATION THAT IS EXEMPT FROM CCPA. THE COURTESY DISCLOSURES ARE MADE WITH A RESERVATION OF ALL RIGHTS THAT WE HAVE UNDER CCPA.

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1.2. Categories of Personal Information We Collect:

We collect the following categories of personal information:

1. “Sensitive Personal Information” such as Social Security numbers (SSNs), Driver’s license, financial account or card numbers, Precise geolocation, Racial and ethnic characteristics, Religious and philosophical beliefs, Union membership, Contents of mail, email and text messages, Genetic and biometric data.
2. “Identifiers” such as name, alias, address, unique identifier, internet protocol address, email address, account number, Social Security Number, or government identification number;
3. “Other Personal Information” such as 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. Some personal information included in this category may overlap with other categories;
4. “Protected Characteristics” under California or federal law for classifications such as 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, or veteran or military status;
5. “Commercial Information” such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
6. “Internet or Network Activity” such as browsing history, search history, information on a consumer's interaction with a website, application, or advertisement;
7. “Biometric Information” such as 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, or gait;
8. “Geolocation” such as physical movements or location;
9. “Sensory Data” such as audio, electronic, or visual information when you participate in telephone screens or video interviews with us;
10. “Professional or Employment Related Information” such as current or past job history or performance evaluations; and
11. “Inferences” such as profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

1.3. How We Obtain Your Personal Information:

1.4. How We Use Your Personal Information

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We may collect, use, or disclose the personal information we collect for one or more of the following purposes:

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Performing services such as maintaining or servicing accounts, providing customer service, processing, or fulfilling transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services, providing storage, or providing similar services on behalf of us or mortgage lenders and brokers. Examples of such activities:

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1. To fulfill or meet the reason for which the information is provided.
2. To allow lenders to underwrite your loan application.
3. To verify the accuracy of information provided on your loan application such as address, employer, bank account information, and credit history.
4. To provide you with information, products, or services that you request from us.
5. To provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you.
6. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
7. To maintain a business-to-business relationship with you.
8. For internal record-keeping purposes.
9. To administer surveys, sweepstakes, promotions, or contests.

1.5. How Long We Retain Your Personal Information

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Absent contractual requirements in our role as service provider and/or legal requirements to the contrary, such as a legal hold, personal information is maintained for a specified period of time, as required by legal, regulatory, or industry requirements, as well as for business purposes.

1. Sensitive Personal Information -
2. Identifiers –
3. Other Personal Information –
4. Protected Characteristics –
5. Commercial Information –
6. Internet or Network Activity -
7. Biometric Information –
8. Sensory Data -
9. Professional or Employment Related Information –
10. Inferences –

1.6. Who We Disclose Your Personal Information To:

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We may disclose your personal information to a service provider, contractor, or third party. When we disclose personal information to a service provider or contractor, 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 or as otherwise allowed under the CCPA. We disclose personal information to third parties as follows:

1. With partners we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Biometric Information, Geolocation, Sensory Data, Professional or Employment Related Information, and Inferences.
2. With mortgage lenders and brokers we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Biometric Information, Geolocation, Sensory Data, Professional or Employment Related Information, and Inferences.
3. With user access, customer service, and quality assurance applications we disclose Identifiers and Other Personal Information.
4. With identity verification services we disclose Sensitive Personal Information, Identifiers, Other Personal Information, and Biometric Information.
5. With application development companies and location finders we disclose Identifiers and Other Personal Information.
6. With customer service survey companies we disclose Identifiers and Other Personal Information.
7. With shipping providers we disclose Identifiers and Other Personal Information.
8. With marketing providers we disclose Identifiers and Other Personal Information.
9. With our data analytics, network monitoring services, and incident response providers, we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, and Biometric Information.
10. With our advisors such as lawyers, banks, and insurers, we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Biometric Information, Geolocation, Sensory Data, Professional or Employment Related Information, and Inferences.
11. With our governmental and regulatory agencies, we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Biometric Information, Geolocation, Sensory Data, Professional or Employment Related Information, and Inferences.
12. With law enforcement, government entities, courts, and pursuant to legal process where required by law, we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Biometric
13. Information, Geolocation, Sensory Data, Professional or Employment Related Information, and Inferences.

1.7. Sale of Personal Information:

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We do not sell your personal information. We do not sell the personal information of minors under 16 years of age without affirmative authorization.

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1.8. Sharing of Personal Information:

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The CCPA defines sharing as renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer’s personal information by the business to a third party for cross‐context behavioral advertising, whether or not for monetary or other valuable consideration. Some of the cookies that our site uses may constitute sharing under the CCPA.

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With our advertising providers, we share Identifiers, Other Personal Information, Internet or Network Activity, Geolocation, and Inferences.

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See below in Section 2.5.2 for instructions on how to opt out of “sharing” your personal information.

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Our website is not aimed at minors and we do not knowingly “share” the personal information of minors under 16 years of age without affirmative authorization.

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2. YOUR RIGHTS UNDER THE CCPA

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The CCPA provides California residents with specific rights regarding their personal information - the Right to Know, the Right to Delete, the Right to Correct, the Right to Limit use of Sensitive Personal Information, the Right to Opt-Out of the Sale of Personal Information or Sharing of Personal Information, and the Right to Non-Discrimination. This section describes your CCPA rights and explains how to exercise those rights, if applicable.

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2.1. Right to Know:

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You have the right to request that we disclose certain information to you about our collection, use, and disclosures of your personal information (“Right to Know”). Once we receive and verify your request, we will disclose to you:

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Categories of Personal Information Collected, Disclosed, Sold, and/or Shared

1. The categories of personal information we collected about you.
2. The categories of sources for the personal information we collected about you.
3. Our business or commercial purpose for collecting that personal information.
4. The categories of third parties with whom we share that personal information.
5. If we disclosed your personal information for a business purpose, the categories of personal information shared with each category of third party recipients.
6. If we sold or shared your personal information for cross-contextual behavioral advertising, the categories of personal information sold or shared.

Specific Information

1. The specific pieces of personal information we collected about you.

We may deny your Request to Know if we are unable to verify your identity or have reason to believe that the request is fraudulent. We may also deny your request if the personal information is subject to an exemption under FCRA, GLBA, or CalFIPA.

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2.3. Right to Correct:

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You have the right to request that we correct your personal information if it is inaccurate (Right to Correct). Once we verify your identity and confirm that your personal information is inaccurate, we will correct your personal information (and direct our service providers to do the same).

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We may deny your Request to Correct if we are unable to verify your identity or have reason to believe that the request is fraudulent. We may also deny your request if the personal information is subject to an exemption under FCRA, GLBA, or CalFIPA.

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2.4. Right to Limit the Use of Sensitive Personal Information:

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You have the right to direct a business that collects your sensitive personal information to limit its use to uses which are necessary to perform the services or provide the goods reasonably expected. However, we only use Sensitive Personal Information to provide the goods and services requested by you; to prevent, detect, and investigate security incidents; to resist malicious, deceptive, fraudulent, or illegal actions and to prosecute those responsible for such actions; to ensure people’s physical safety; to perform services on our behalf; to verify or maintain the quality or safety of our products, services, and devices.

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2.5. Right to Opt-Out and How to Submit a Request to Opt-Out

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The CCPA gives consumers the right to opt-out of 1) the sale of their personal information, 2) the “sharing” of their personal information for cross-context behavior advertising, or 2) for use in automated decision making.

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2.5.1. Sale of Personal Information

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We do not sell your personal information. We do not sell the personal information of minors under 16 years of age without affirmative authorization.

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2.5.2. Sharing Information for Cross-Contextual Behavioral Advertising

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To opt out of “sharing” for cross-contextual behavioral advertising you may use the Global Privacy Control (GPC) for your browser. To learn more about how to enable GPC in participating browsers, visit www.globalprivacycontrol.org/

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2.5.3. Automated Decision Making

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The CCPA gives consumers the right to opt-out of the use of automated decision-making technology in connection with decisions about the consumer’s work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. However, we do not use automated decision-making technology for personal information that is not covered by FCRA, GLBA, and/or CalFIPA.

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2.6. Right to Non-Discrimination:

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We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or services, charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, provide you a different level or quality of goods or services, suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

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3. SUBMITTING A REQUEST TO KNOW, REQUEST TO DELETE, REQUEST TO CORRECT

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3.1. How to submit a request:

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To make a Request to Know, Request to Delete or Request to Correct, please contact us by either:

• Calling us at: [insert toll free number]
• Complete the CCPA Request form at: [insert webform]

Only 1) you or 2) a person authorized by you to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a request on behalf of your minor child.

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You may only make a Request to Know twice within a 12-month period.

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A Request to Know, Request to Delete, or Request to Correct must:

1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
3. If you are submitting a Request to Know specific pieces of personal information, you will need to submit a declaration under the penalty of perjury confirming you are only correcting information about yourself.

3.2. Authorized Agents

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Before we can respond to a Request to Know, Request to Delete, or Request to Correct submitted by an authorized agent, we need to verify not only that person or entity’s authority to act on your behalf but also verify the identity of the authorized agent.

If you are authorized to submit a request on behalf of a California resident, please email us at: privacy@cloudviega.com and provide the following information:

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1. To verify your authorization to request on behalf of a California resident, please attach a copy of one or more of the following to your request email:

1. written permission from the California resident, or
2. a valid power of attorney

2. To verify your identity, please attach copies of the following to your request email:

1. Valid Government Issued ID (not expired) AND
2. a utility bill, bank statement, or similar documentation to verify your name and address.

3. To verify the identity of the consumer for whom you are submitting the request, please attach three or more of the following with your request email:

1. name,
2. address,
3. date of birth,
4. email address,
5. phone number,
6. last 4 of the Social Security Number, or
7. last 4 of the account number

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 the personal information relates to you. We will only use personal information provided in a request to verify the requestor's identity or authority to make the request.

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3.3. Response Timing and Delivery Method:

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We will acknowledge receipt of your request within 10 business days of its receipt. We will respond to a request within 45 days of its receipt. If 3we 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. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

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We do not charge a fee to process or respond to your 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.

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4. SOCIAL MEDIA

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We encourage you to review your privacy options and settings with the social media platforms and networks you use to understand what choices you have about disclosing your information through those platforms and networks with us.

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5. CHANGES TO OUR PRIVACY POLICY

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We reserve the right to amend this California Privacy Policy at our discretion and at any time. When we make material changes to this privacy policy, we will notify you by email or through a notice on our website homepage.

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6. HOW TO CONTACT US

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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, or wish to exercise your rights under California law, please do not hesitate to contact us at:

1. Privacy Support Phone: [insert toll free number]
2. Privacy Support E-Mail: privacy@cloudvirga.com
3. Postal Address: CLOUDVIRGA, Inc.
   Attn: Legal Department
   5291 California Ave., Suite 300
   Irvine, CA 92617

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Effective Date TBD

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