Privacy Notice – CCPA

CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act (CCPA) provide certain protections to California residents concerning the collection and use of personal information, unless an exception applies. In compliance with federal and state law, Best Egg is fully committed to handling the personal information and the data of consumers responsibly with respect and due care.

The CCPA does not apply to information subject to the federal Gramm-Leach-Bliley Act (“GLBA”) and Fair Credit Reporting Act (“FCRA”).  It also does not apply to information that cannot be associated or reasonably linked with a particular consumer or household.  As a financial services platform, most of the information Best Egg collects and shares is exempt from the CCPA because it is subject to GLBA and FCRA or cannot be associated or reasonably linked with a particular consumer or household.

If you are a California resident and the CCPA applies, California law provides you with specific rights regarding your personal information and data. These rights are described below in the section below titled Your Rights as a California Resident. Please note that we are only required to respond to two such requests per consumer each year.

Collection of Personal Information

In the past 12 months, we have collected the following categories of Sensitive Personal Information and other Personal Information relating to California residents covered by this Notice:

Sensitive Personal Information

• Identifiers, such as name and government-issued identifier (e.g., Social Security number);
• Biometric information, such as voiceprints; and
• Geolocation data, such as device location and Internet Protocol (IP) location.

_{Sensitive Personal Information that is publicly available is not considered Sensitive Personal Information.}

Other Personal Information

• Audio, electronic, visual, and similar information, such as call and video recordings;
• Professional or employment-related information, such as work history and prior employer;
• Education information, such as student records and directory information;
• Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.
• Personal information, as defined in the California safeguards law, such as contact information and financial information;
• Commercial information, specifically transaction information and purchase history; and
• Internet or network activity information, such interactions with our website.

_{Information about a California Resident that is publicly available is not considered Personal Information.}

The categories of sources from whom we collected this Sensitive Personal Information and other Personal Information are:

• Directly from you as a California resident or the individual’s representatives
• Service Providers, Consumer Data Resellers and other third parties
• Public Record Sources (Federal, State or Local Government Sources)
• Information from our Affiliates and Bank Partners
• Website and Social Media

Disclosure of Personal Information

The categories of third parties to whom we disclosed Sensitive Personal Information and other Personal Information for our business purposes described in this Privacy Notice are:

• Bank Partners, Investors, Affiliates and Subsidiaries of Best Egg
• Vendors and Service Providers who provide services such as website hosting, data analysis, payment processing, information technology and related infrastructure, customer service, email delivery, auditing, marketing, and marketing research activities
• Partners and third parties who provide services such as payment, banking, communications, infrastructure, storage, legal expertise, tax expertise, notaries, and auditors
• Third parties who enable customers to conduct business online such as aggregators (at the direction of the customer)
• Other third parties to comply with legal requirements such as the demands of applicable subpoenas and court orders; to verify or enforce our terms of use, our other rights, or other applicable policies; to address fraud, security, or technical issues; to respond to an emergency; or otherwise, to protect the rights, property, or security of our customers or third parties
• Government Agencies as required by laws and regulations

Use of Personal Information

In the past 12 months, we have used Sensitive Personal Information and other Personal Information relating to California residents to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including the following:

• Performing services, including maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, processing payments, advertising, or marketing, providing analytic services, or providing similar services
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
• Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the business
• Debugging to identify and repair errors that impair existing intended functionality
• Undertaking internal research for technological development and demonstration
• Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance or opinions)

Sale of Personal Information

In the past 12 months, we have not “sold” or shared for cross-context behavioral advertising Sensitive Personal Information and other Personal Information subject to CCPA, including Sensitive Personal Information and other Personal Information of minors under the age of 16. For purposes of this Notice, “sold” means the disclosure of Personal Information to a third-party for monetary or other valuable consideration. Because we have not sold or shared Sensitive Personal Information or other Personal Information subject to CCPA in the last 12 months, we do not offer an opt out from the sale of Personal Information.

Data Retention

Best Egg will retain your Sensitive Personal Information and other Personal Information to the extent necessary to comply with our legal obligations, resolve disputes, enforce our legal agreements and policies, and conduct business. Best Egg will retain data for internal analysis to improve our product and service offerings and enhance the service to our future and existing customers. In compliance with CCPA, Best Egg is fully committed to managing and protecting your personal information and data responsibility with respect and due care.

YOUR RIGHTS AS A CALIFORNIA RESIDENT

Listed below is a summary of the rights you are entitled to as a California resident under the CCPA, unless an exception applies:

• To request information about yourself and your data that has been collected, used, disclosed, shared, or sold;
• To request information be deleted, subject to certain exceptions, including compliance with applicable laws and regulations.;
• To request the disclosure of the categories of personal information and data collected, the categories of sources, the purpose of collection, selling, or sharing such information, the categories of information and data that has been shared or sold along with the business purpose, the categories of third parties to whom we have disclosed personal information, and the specific pieces of information we have collected about you;
• To opt-out of the sale or sharing of certain personal information and data. Please note that the collection and disclosure of certain information and data is needed to comply with federal law and to provide certain products and services;
• To be free from discrimination for exercising your rights.;
• Request to correct any inaccuracies about your personal information; and
• Limit the use of sensitive personal information and data.

If you wish to exercise your CCPA rights or if you are an agent seeking to exercise CCPA rights, you may submit your request online. You may also contact Best Egg at (866) 615-4323 to submit a request or to ask any questions about our privacy practices.

Once we receive your request, we may verify your identity through your account or by requesting additional information sufficient to confirm your identity.
This Policy is subject to change. Please review it periodically. If we make changes, we will revise the “Last Updated” date at the bottom of this Policy. Any changes will be effective when we post the revised Policy on the website.  Your continued use of our website constitutes your acceptance of any changes or revisions to this Notice..

_{Last Updated: 12/2022}