Last updated on January 30, 2024
The California Consumer Privacy Act ("CCPA") grants residents of the State of California (hereinafter “you”) certain privacy rights regarding their personal information. The CCPA requires that a business that collects personal information from a natural person disclose, at or before the point of collection, the categories of personal information to be collected and the purposes for which that information is to be used. This Privacy Policy is intended to meet that requirement and supplements our online Privacy Policy.
Capital on Tap dba New Wave Capital LLC (“Company,” “we,” “us,” or “our”) provides this Privacy Policy to California residents. This Privacy Policy sets forth our practices with respect to information that can reasonably be linked with an individual or household (“Personal Information”), as required by the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”).
This Privacy Policy only applies to residents of the State of California.
Below is a summary of what you will find in this Privacy Policy:
● Personal Information
● Personal Information We Collect
● Where do We Collect Your Personal Information From
● Purposes for which We Use, Collect, and Disclose Personal Information
● How We May Use or Disclose Your Personal Information
● Our Cookies Policy
● Changes to this Privacy Policy
● Full Privacy Policy
● Contact Information
The CCPA defines personal information as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
Personal information under the CCPA, however, does not include:
● Deidentified or aggregated consumer information.
● Publicly available information from federal, state or local government records.
Information excluded from the scope of the CCPA such as personal information covered by certain sector-specific privacy laws such as the Fair Credit Reporting Act (“FCRA”) (information relating to your credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, and mode of living), the Gramm-Leach-Bliley Act (“GLBA”) (financial information privacy), or California Financial Information Privacy Act (“CFIPA”) and the Driver’s Privacy Protection Act of 1994.
We have collected and may collect or receive the categories of Personal Information listed below. Not all categories will be collected or received for every individual.
● Identifiers, such as name, address
● Device and online identifiers, and related information, such as telephone number and email address
● Demographic information, such as age and date of birth
● Characteristics of protected classifications under state or federal law, such as gender and nationality
● Commercial information, such as background information, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
● Financial information, such as credit, and fraud information, financial institution account information
● Biometric Information, such as a facial geometry scan or “faceprint.” We may engage third party vendors to obtain biometric information for the purposes of fraud prevention or identity verification. We currently work with Persona for these purposes, more information on their privacy policy can be found HERE.
● Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website application, or advertisement.
● Audio, electronic, visual, thermal, olfactory, or similar information, such as audio recordings or email and chat communications
● Location information, such as geo-location information
● Professional or employment-related information, such as occupation, title, licenses
● Sensitive personal information, such as social security, driver's license, state identification card, or passport number, account log-in, financial account, debit card, or credit card number, a consumer's precise geolocation.
Typically, we will collect information from you when you contact us directly or provide information to us to provide you with our products and services. In addition, we collect information from and about you in the following ways:
● You (or your representative)
● Data Analytics Providers
● Marketing Partners
● Our website and mobile applications
● Social Media Websites
● Services Providers
● Government Agencies
● Publicly accessible databases
● To create and/or maintain your credit account
● To fulfill requests and obligations related to our relationship
● To conduct auditing and monitoring of transactions and engagement
● To protect the security and integrity of our websites, mobile services, and our business
● To help prevent fraud
● Debugging to identify and repair errors that impair existing intended functionality
● To update our operational and technical functionality
● To conduct business analysis, such as analytics, projections, identifying areas for operational improvement
● To conduct research and development
● Operate and manage Information Technology and communications systems and facilities, allocate Company assets, and undertake strategic planning and project management; and
● Comply with law, legal process, requests from governmental or regulatory authorities, internal policies, and other requirements, such as income tax deductions, recordkeeping, work permit, and immigration regulations and reporting obligations, and the exercise or defense of legal claims.
We will only use your Personal Information for the reasons for which we collected it. If we need to use your Personal Information for another purpose, we will tell you about it, explain the legal basis which allows us to do so, and obtain your explicit consent.
We may need to provide Personal Information to third parties for a variety of business or commercial reasons; for example, we may need to provide information to assist in the management of your accounts with us or the detection or prevention of crime. We only obtain, use, and keep Personal Information where we need it for a specific business or commercial purpose. The following is a list of the categories of Personal Information that we may have disclosed for a business purpose to third parties in the preceding 12 months along with the categories of third parties to whom the information may have been disclosed:
● Identifiers: We may share this information with subsidiaries and affiliates, with subcontractors, service providers, and other vendors to which access to the Personal Information is required to fulfill the work being performed or requests made by you or Capital on Tap or with third party servicers to whom debt may be sold.
● Device and online identifiers: We may share this information with subsidiaries and affiliates, with subcontractors, service providers, and other vendors to which access to the Personal Information is required to fulfill the work being performed or requests made by you or Capital on Tap.
● Demographic information: We may share this information with subsidiaries and affiliates, with subcontractors, service providers, and other vendors to which access to the Personal Information is required to fulfill the work being performed or requests made by you or Capital on Tap.
● Characteristics of a protected classification: We may share this information with We may share this information with subsidiaries and affiliates, with subcontractors, service providers, and other vendors to which access to the Personal Information is required to fulfill the work being performed or requests made by you or Capital on Tap.
● Commercial information: We may share this information with subsidiaries and affiliates, with subcontractors, service providers, and other vendors to which access to the Personal Information is required to fulfill the work being performed or requests made by you or Capital on Tap or with third party servicers to whom debt may be sold.
● Biometric Information: We may share this information with subsidiaries and affiliates, with subcontractors, service providers, and other vendors to which access to the Personal Information is required to fulfill the work being performed or requests made by you or Capital on Tap.
● Internet or other electronic network activity: We may share this information with subsidiaries and affiliates, with subcontractors, service providers, and other vendors to which access to the Personal Information is required to fulfill the work being performed or requests made by you or Capital on Tap.
● Audio, electronic, visual, thermal, olfactory, or similar information: We may share this information with subsidiaries and affiliates, with subcontractors, service providers, and other vendors to which access to the Personal Information is required to fulfill the work being performed or requests made by you or Capital on Tap.
● Location Information: We may share this information with subsidiaries and affiliates, with subcontractors, service providers, and other vendors to which access to the Personal Information is required to fulfill the work being performed or requests made by you or Capital on Tap.
● Professional or employment-related information: We may share this information with We may share this information with subsidiaries and affiliates, with subcontractors, service providers, and other vendors to which access to the Personal Information is required to fulfill the work being performed or requests made by you or Capital on Tap.
● Sensitive Personal Information: We may share this information with subsidiaries and affiliates, with subcontractors, service providers, and other vendors to which access to the Personal Information is required to fulfill the work being performed or requests made by you or Capital on Tap or with third party servicers to whom debt may be sold.
We may disclose your Personal Information for one or more of the following business or commercial purposes:
● To create and/or maintain your credit account
● To fulfill requests and obligations related to our relationship
● For purposes of performing services for our business, providing services as requested by you, and ensuring the safety, security, and integrity of our business, infrastructure, and the individuals with whom we interact.
● To conduct auditing and monitoring of transactions and engagement
● To protect the security and integrity of our websites, mobile services, and our business
● To help prevent fraud
● To update our operational and technical functionality
● To conduct business analysis, such as analytics, projections, identifying areas for operational improvement
● To conduct research and development
● Operate and manage IT and communications systems and facilities, allocate Company assets, and undertake strategic planning and project management
● Any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings); and
● Comply with law, legal process, requests from governmental or regulatory authorities, internal policies, and other requirements, such as income tax deductions, recordkeeping, work permit, and immigration regulations and reporting obligations, and the exercise or defense of legal claims.
We do not and will not sell or share (for cross-contextual behavioral advertising) your Personal Information to any third party, nor have we done so in the preceding 12 months. Similarly, we do not and will not collect, sell, or share (for cross-contextual behavioral advertising) the Personal Information of minors under 16 years of age.
We only collect or use sensitive Personal Information for the following business or commercial purposes:
● To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
● To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted Personal Information.
● To resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for those actions.
● To ensure the physical safety of natural persons.
● For short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us.
● To perform services on our behalf.
● To verify or maintain the quality or safety of a product, 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 by, manufactured for, or controlled by us.
● To collect or process sensitive Personal Information where such collection or processing is not for the purpose of inferring characteristics about a consumer.
You can read our full cookies policy here: https://www.capitalontap.com/us/legal/cookies-policy/.
The CCPA provides you with certain rights regarding the collection, use, and disclosure of your Personal Information. As described in more detail below, the CCPA provides you with the following rights:
o The categories of Personal Information (including Sensitive Personal Information) we collect, the business or commercial purpose for which we collect and use the Personal Information, and whether we sell or share that information; and
o How long we intend to keep each category of Personal Information, including Sensitive Personal Information.
You also have the right to request that we provide you with certain information about the Personal Information we collect, use, share, disclose, or sell, as well as the categories and specific pieces of information that we have collected about you. Specifically, you have the right to request the following information:
You also have the Right to Opt-Out of the sale or sharing (for targeted advertising) your Personal Information. However, we do not sell or share your Personal Information.
To exercise your Right to Know, Correct, or Delete your Personal Information, please submit a request to us by:
● Phone: 1-833-972-1323
● Email: support@capitalontap.com
● Mail: 675 Ponce De Leon Ave NE Suite 8500, Atlanta, GA 30308
We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you in order to verify your identity and protect against fraudulent requests. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information. We will verify and respond to your request in compliance with the timeframes set forth in the CCPA.
If you request access to, or the correction or deletion of, your Personal Information we will verify your identity before disclosing the requested information. To do so, we may ask that you log into your account or provide us with your:
● Business Name*
● Personal Guarantor's First name*, Middle initial, Last name*
● Address*
● Email address
● Phone number
*Required field
When you make a request, you will be asked to answer a few questions about yourself to help us verify your identity. Third-party identification services may help us with verification to prevent the disclosure of your Personal Information resulting from fraudulent requests. You may be asked to log into your online account to complete this request or provide the information described above. In the event more documentation is necessary to verify your identity, we will notify you directly.
If we can’t verify your identity, we will notify you, and your request(s) to access, request, or delete your Personal Information may not be processed. Any requests may be denied if we have reason to believe they are fraudulent.
If you’d like an authorized agent to exercise your rights for you, they may use the same methods described above to submit requests. We require documentation demonstrating your agent’s authority to submit requests on your behalf. For example, a valid power of attorney or other documentation, including a letter, signed by you (the California resident) authorizing the agent to submit your requests. Documentation may be uploaded at the time you submit your request on our website or provided to us up to 10 business days after. If you submit your request by calling, you can email to support@capitalontap.com.
We reserve the right to change this Policy at any time without prior notice. If we update this Policy, we will notify you by posting a new version on this page. Please check here regularly to learn of any changes. We will post the date of the most recent Privacy Policy at the top of this page.
This California Privacy Policy was last updated on January 30, 2024.
Our full Privacy Policy can be accessed here.
We will keep the Personal Information we collect about you for as long as necessary to carry out the purposes set forth in this Privacy Policy or any other notice provided at the time of data collection, but no longer than as required or permitted under applicable law or internal Company policy. We dispose of the information we collect in accordance with Company retention policies and procedures.
If you have any questions or comments about this Privacy Policy, the ways in which the Company collects and uses your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Website: www.capitalontap.com/us/
Email: support@capitalontap.com
Phone: 1-833-972-1323