Effective Date: 12/1/2023

Last Reviewed on: 12/27/2023

This Privacy Notice for California Residents supplements the information contained in TOP DEBT OPTIONS Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Introduction

TOP DEBT OPTIONS is an award-winning service which connects consumers with a marketplace of third party Lending Partners, financial service providers, credit card providers and debt relief providers. To assist us in providing our award-winning service, we collect and process your information. We work extremely hard to be good stewards of your information at all times. 

This document is here to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete it. 

Information We Collect

The Personal information you provide to us. Personal information you may provide to us when you use the service such as:

• Contact data, such as your first and last name, email address, residential address and phone number.
• Identity data, such as your Social Security number and date of birth.
• Credit history and loan data, such as your estimated credit score, vehicle and home ownership status and other information.
• Employment data, such as your employment status, employer name, and income
• Education data, such as the education level you have obtained.
• Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Other sources. As part of our service we may receive information from the Partners we connect you with including, but not limited to status of product acceptance and funding, and loan terms offered and obtained (such as APR, repayment amount, loan amount). As part of our service we may also receive information from Transunion when we perform a soft credit check including but not limited to your credit score and profile. We may combine personal information we receive from you with information we obtain from other sources, such as:

• Data providers, such as credit bureaus and information services.
• Business partners, third parties, Lending Partners, or affiliates, as well as other information provided to us online or offline by customers or users of applyspf.com

Automatic Collection. We, our service providers and our third party partners may automatically capture information about you, your computer or mobile device, and your activity over time on the service and other online services, including:

• Online activity data, such as the date and time of your access, visit or use of the service, and information about your activity on a page or screen.
• Device data, such as unique device identifier, media access control address, network information, hardware model, browser type, screen resolution, IP address as well as usage and traffic data and information about how the device interacts with the service.

Cookies and Similar Technologies. To assist the services in collecting and storing Non-Personal Information, we may employ a variety of technologies, including “Cookies,” local browser storage and “Web Beacons”:

• Cookies, A “Cookie” is a small amount of data a website may store in your web browser that it can access when you visit it. A cookie also refers to web-browser-based storage provided by Adobe’s Flash plugin (a “Flash Cookie”). Cookies may contain user preferences, unique identifiers and other Non-Personal Information. See our Cookie Policy for more information on how cookies are used and how to manage your preferences.
• Web beacons, A “Web Beacon” is a small, usually-transparent image placed on a web page that allows us or our partners to collect non-Personal Information.

How We Use Your Personal Information 

We may use, sell, or disclose the personal information we collect for one or more of the following business purposes listed below. 

Service delivery We may use your personal information to:

• Provide, deliver, and customize your use of the TOP DEBT OPTIONS service;
• Connect you with partners, Lending Partners, aggregators, and/or loan originators and send you service-related information;
• Communicate with you about the service and to respond to your inquiries, including for Customer support;
• Send you important information regarding the services, changes to our terms, conditions, and Policies and/or other administrative information.
• Understand your needs and interests, and personalize your experience with the service and our communications; 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 the business, and to improve, 

Research and development. We may use your personal information for research and development purposes, including to perform research and analysis aimed at improving our products and services. We make personal information into anonymous data by removing information that makes the data personally identifiable in order to share it with third parties for our lawful business purposes, including to analyze and improve the service and promote our business.

Marketing and advertising. With your consent, we and our third party advertising partners and business partners may use your personal information for marketing and advertising purposes:

• Direct marketing. We may send you TOP DEBT OPTIONS related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications from TOP DEBT OPTIONS by Unsubscribing. 
• Interest-based advertising. We may partner with third-party companies to display ads on the service and other sites. These companies may use cookies and similar technologies to try to tailor the ads you see online to your interests based on your activity over time across the service and other sites, or your interaction with our emails. These ads are known as "interest-based advertisements." For more information on these advertisements and to manage your preferences, visit our Terms 

Compliance and protection. We may use your personal information to:

• Comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government authorities.
• Perform debugging to identify and repair errors that impair existing intended functionality
• Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• Enforce the Terms of Service; and
• Detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

For other purposes. We may also use your personal information for other purposes described in this Privacy Policy or at the time we collect the information, as permissible by law. TOP DEBT OPTIONS will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.       

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How We Share Your Personal Information 

TOP DEBT OPTIONS may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection. 

• Advertisers: Third party companies that we use to advertise our services, and/or deliver ads to you and similar users on their platforms or through email marketing
• Authorities: Law enforcement, government authorities, privacy parties, and other applicable authorities
• Business Partners: Third party companies that we partner with to provide content or services to you or to such business partners. Such as affiliates, data brokers, and lending partners (please see our Partner List for more information on our network of lending partners)
• Internet Cookie Data Recipients
• Parent or Subsidiary Organizations
• Professional advisors: Such as professional advisors, lawyers, bankers, auditors or insurers
• Service providers: Such as credit bureaus and information services.
• For other purposes: We may also share your personal information for other purposes described in this Privacy Policy or with your consent

Your Choices

• Marketing communications. To Opt-out of email marketing, email us at info@topdebtoptions.com or submit your email address here. TOP DEBT OPTIONS will comply with your unsubscribe request within ten days of submission, as required by law. You may continue to receive service-related and other non-marketing emails.
• Cookies. See our Cookie Policy for more information on how cookies are used and how to manage your preferences.
• Advertising choices. See our Terms for more information on how to manage your targeted advertising preferences.
• Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. At this time, TOP DEBT OPTIONS.com does not respond to "do not track" signals that may be sent from your browser.
• Declining to provide personal information. If you do not provide certain information that is needed to deliver the TOP DEBT OPTIONS service, we may not be able to provide you with all or certain features of the service.

Your Rights as a California Resident

As a California resident, you have the rights listed below. These rights are not absolute and subject to certain exceptions; we may decline your request in certain cases as permitted by law.

• Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
  • The categories of Personal Information that we have collected.
  • The categories of sources from which we collected Personal Information.
  • The business or commercial purpose for collecting and/or selling Personal Information.
  • The categories of third parties with whom we share Personal Information.
  • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
  • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
• Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to forty-five) 45 days, we will inform you of the reason and extension period in writing. If applicable, the response we provide will explain the reasons we cannot comply with a request. 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 you with a cost estimate before completing your request.
• Deletion. You can ask us to delete the Personal Information that we have collected from you. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to forty-five (45) days, we will inform you of the reason and extension period in writing. If applicable, the response we provide will explain the reasons we cannot comply with a request.
•  Opt-out of sales. If we sell your Personal Information, you can opt-out. 
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our service. 

How to exercise your rights. You may exercise your California privacy rights described above as follows:

• Right to information, access, deletion, and Opt-out. You can request to exercise your information, access, deletion, and Opt-out rights by:
  • Submitting a request through our Terms
  • Emailing info@topdebtoptions.com

We reserve the right to confirm your identity and California residency status to process your requests to exercise your information, access or deletion rights. As part of this process, government identification may be required. 

Personal information that we collect, use and share.

The chart below summarizes how we collect, use and share Personal Information by reference to the categories specified in the CCPA, and describes our practices during the 12 months preceding the effective date of this Privacy Policy.

Categories in the chart refer to the categories described above in the general section of this Privacy Policy. If a category of information is not listed within the chart (such as Biometric Information or Inferences) then those categories of information are not collected by TOP DEBT OPTIONS. 

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@topdebtoptions.com or write to us at: 8595 Pelham Rd Suite 400 #839, Greenville, SC 29615.