Last Updated: August 22, 2022

California Consumer Privacy Act Notice for California Consumers

This California Consumer Privacy Act Notice for California Consumers (“CCPA Notice”) supplements the True Link Privacy Policy and is provided by True Link Financial Inc. and its subsidiary, True Link Financial Advisors, LLC (collectively, “True Link,” “Company”, we,” “our” or “us”)The California Consumer Privacy Act (“CCPA”)affords California consumers certain rights over their personal information(subject to certain exceptions). This CCPA Notice outlines those rights and explains how such rights may be exercised. This CCPA Notice also summarizes our data collection and sharing practices, as required by the CCPA. Terms used but not defined shall have the meaning ascribed to them in the CCPA. Please note that this notice applies exclusively to California residents.

Applicability
This Notice explains how True Link collects, uses, and discloses personal information relating to California residents covered by the CCPA. Under the CCPA, “Personal Information” is any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.

Personal information does not include:

1. What Information is Covered by this CCPA Notice?

This CCPA Notice relates to the Company’s collection, use and disclosure of California consumers’ personal information. “Personal information” generally means information that is reasonably capable of being associated with you or your household. In the preceding 12 months, we have collected the following categories of personal information:

A. Identifiers

including name, Social Security number, address, telephone number, driver’s license or state identification card number, bank account number, or other similar identifiers

B. Online identifiers

including Internet Protocol address, email address, account name, or other similar identifiers

C. Commercial

information, including assets owned, sources of assets, products or services purchased, or other purchasing or consuming histories, and securities transactions

D. Geo location data

including where the True Link Visa Card has been used

E. Internet or other electronic network activity information

including, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement

F. Inferences drawn from any of the categories of information identified above to create a profile

including inferences about an individual’s preference and characteristics (please note: we do not infer information about protected characteristics)

G. Other Information You Provide to Us

including in reviews, questions, and comments that are shared in a public forum or in response to surveys

2. Where We Collect Personal Information From.

For a list of the categories of sources from which we may collect personal information, please see Section 1 of the True Link Privacy Policy (Collection of your Information).

3. How We Use Personal Information.

For information about how we use personal information, please visit Section 4 of the True Link Privacy Policy (Use of Your Information).

4. Personal Information Disclosed for a Business Purpose in the Previous 12 Months.

We may have shared any of the categories of personal information listed above in Section 1 with the following third parties for our business purposes:

Section 5 of our Privacy Policy (Sharing of Your Information) explains these categories of third parties in detail.  For example, Section 5 of our Privacy Policy will explain the types of entities we are referring to when we use the phrase “Service Providers” in this CCPA Notice.  For more information about the business purposes for which we may disclosed personal information, please visit Section 4 of our Privacy Policy (Use of Your Information).

5. Personal Information “Sold” In the Previous 12 Months.

We do not provide personal information about you to other companies for money. We do share personal information with companies that we work with, including to help us market or advertise to you. Even though we do not provide personal information to these companies for money, California law may characterize our providing the following categories of information we share with companies that provide services to you or to us, such as personalizing your experience with us or helping us to market or advertise our products and services to you, as "sales" of personal information:

These categories of personal information may have been “sold” to the following categories of third parties:

6. Your CCPA Rights.

Subject to certain exceptions, the CCPA affords you the following rights with respect to your personal information.  It’s worth noting that these rights do not apply to personal information we collect about California consumers who apply for or obtain a financial product and service for personal, family, or household purposes (in other words, information regulated by the Gramm-Leach-Bliley Act). For information about how we collect, disclose and use information relating to these consumers and the choices relating to such information, please refer to our GLBA Notice.

A. Request to Know.

Subject to certain exceptions, you have a right to request that the Company disclose what personal information it collects, uses, discloses, and sells during the preceding 12 months. Subject to exceptions, it includes a request for any or all of the following:

B. Request to Delete.

Subject to certain exceptions, you have a right to request that the Company delete your personal information that we have collected from you.

C. Request to Opt-Out.

You have a right to request that the Company not “sell” your personal information to third parties.

D. No Discrimination.

You have a right not to receive discriminatory treatment by the Company for the exercise of the privacy rights conferred by the CCPA.

E. CCPA Stats.

(January 1, 2021, to December 31, 2021)

Request Type

Access
Deletion
Opt-Out

Received

0
0
0

Complied With

0
0
0

Denied

0
0
0

Average Days to respond

0
0
0

Received

Access
0
Denied
0
Opt-Out
0

Complied With

Access
0
Denied
0
Opt-Out
0

Denied

Access
0
Denied
0
Opt-Out
0

Avg. Days to Respond

Access
0
Denied
0
Opt-Out
0

7. How to Exercise Your CCPA Rights

A. Submitting a Request to Know or Request to Delete.

You may submit a Request to Know or a Request to Delete by contacting us at this toll-free number, 1-855-244-1209, or by submitting this Request.

B. Submitting a Request to Opt-Out.

True Link does not engage in the sale of personal information as contemplated by the CCPA and therefore we do not offer a means to opt-out.  

C. Verification Methods.

Once you submit a request, we will verify that you are the consumer to which the request pertains by matching your name, email address and physical address with information we maintain.  Depending on the type of request you submit, we will attempt to match either two or three of these data points to the information maintained in our systems.  If we are unable to verify your request with the data points you provided, we may reach out to you for additional information to verify your request.  We may also reach out to you for additional verifying information for requests requiring a higher degree of verification because of the type or sensitivity of the request. In some instances, we may not be able to honor your request, such as when an exception applies or when we cannot verify your identity. All requests for Your Right To Know will be honored within forty-five (45) days of receipt, unless we are unable to process your request in such a time (unless an exception applies) in which case we will provide you an explanation for the delay.

D. Authorized Agent Requests.

You may designate an authorized agent to submit a request on your behalf.  We may require that you provide the authorized agent with written permission to act on your behalf and that you verify your identity directly with us.

8. Alternate Format of CCPA Notice.

If you have a disability that prevents or limits your ability to access this CCPA Notice, please email us at support@truelinkfinancial.com or call us at 1-855-244-1209 We will work with you to provide this notice in an alternative format.

9. Contact for More Information.

If you have any questions or concerns about our privacy policies and practices, please email us at support@truelinkfinancial.com or call us at 1-855-244-1209