Plutus Debt Management LLC
California Consumer Privacy Statement
This California Consumer Privacy Statement (“Statement”) supplements our Plutus Debt Management LLC (“Plutus”) Web Privacy Policy. This Statement applies solely to California consumers, including personnel working on behalf of our business partners (e.g., vendors) (collectively, “B2B individuals”), subject to the exceptions listed below. This Statement does not apply to Plutus’ personnel or job applicants. For clarity, this Statement applies to personal information we collect about California consumers both on the Site and offline. This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (the “CCPA”), as amended by the California Privacy Rights Act of 2020 (the “CPRA”), and its implementing regulations (the “CCPA/CPRA”).
1. Notice of Collection and Use of Personal Information
We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:
- Additional Data Subject to Cal. Civ. Code § 1798.80: signature
- Identifiers: identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, or other similar identifier
- Online Activity: Internet and other electronic network activity information, including, but not limited to, information regarding your interaction with websites, applications or advertisements
- Sensory Information: audio, electronic, and similar information.
- Employment Information: professional or employment-related information
We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our Privacy Policy and for the following Business Purposes specified in the CCPA/CPRA:
- Providing advertising and marketing services to you, except for cross-context behavior advertising (which is addressed in Section 4 of this Statement);
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
- Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us;
- Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes;
- Debugging to identify and repair errors that impair existing intended functionality;
- Undertaking internal research for technological development and demonstration; and
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
We do not collect or process sensitive personal information with the purpose of inferring characteristics about California consumers covered by this Statement.
2. Retention of Personal Information
We will retain your personal information for the time period reasonably necessary to achieve the purposes described in our Privacy Policy and this Statement, or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.
3. Sources of Personal Information
During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:
- Directly from you or your devices, for example, through your use of the Website
- Our affiliates or subsidiaries
- Your employer, if you are a representative of a vendor or other business partner
- Other individuals, such as in connection with a business referral
- Vendors who provide services on our behalf
- Data analytics providers
- Government entities
4. Sale or Sharing of Personal Information
We do not (and will not) sell personal information, or share personal information for cross-context behavioral advertising purposes, unless we post a notice of the right to opt out of such sale or sharing and comply with other relevant legal requirements. We do not sell sensitive personal information or share sensitive personal information for purposes of cross-context behavioral advertising.
5. Disclosure of Personal Information
During the 12-month period prior to the effective date of this Statement, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:
| Category of Personal Information | Category of Third Party |
| Identifiers | Our affiliates and subsidiaries Vendors who provide services on our behalf Professional services organizations, such as law firms and independent auditors Data analytics providers |
| Online Activity | Our affiliates and subsidiaries Vendors who provide services on our behalf Professional services organizations, such as law firms and independent auditors Data analytics providers |
| Sensory Information | Our affiliates and subsidiaries Vendors who provide services on our behalf Professional services organizations, such as law firms and independent auditors Data analytics providers |
In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have disclosed personal information about you to government entities, such as in response to a request from law enforcement authorities.
6. California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.Right to Know: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold or shared about you during the past 12 months.
Right to Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
Right to Deletion: You have the right to request that we delete certain personal information we have collected from you.
Right to Opt-Out of Sale or Sharing: You have the right to opt-out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising purposes.
As described above, we do not sell personal information or share personal information for cross-context behavioral advertising purposes.
How to Submit a Request
To submit an access, correction or deletion request, email us at cs@plutusdb.com or call us at [phone]. To submit a request as an authorized agent on behalf of a consumer, please email us at cs@plutusdb.com and provide us with a copy of the signed permission from the California consumer that authorizes you to act on the consumer’s behalf. For questions or concerns about our privacy policies and practices, please contact us as described in the How to Contact Us section of our Privacy Policy.
B2B Individuals: If you are personnel working on behalf of our business partners (e.g., vendors), to submit an access, correction or deletion request, please email us at b2b@plutusdb.com or call us at 1-[phone].
Verification
To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you do not have an email address or other direct contact information on file with us, then there is no reasonable method by which we can verify your identity to the level of certainty required by the CCPA/CPRA. The reason for this is that we do not link IP addresses, device identifiers or other information collected through automated means to named actual persons. Accordingly, if you do not have an email address or other direct contact information on file with us, and you request access to, or correction or deletion of, your personal information, we will not be able to process your request at this time.
If you have an email address or other direct contact information on file with us, and request access to, or correction or deletion of, your personal information, we may require you to provide your name and email address. In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Additional Information
f you choose to exercise any of your rights under CCPA/CPRA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.