Privacy Notice for California Residents

This Privacy Notice for California Residents (“Privacy Notice”) supplements the information contained in the "MoneySmartUSA" Privacy Policy (the “Privacy Policy”) made available on the Website located at (the “Website”). The Website is owned and operated by Red Mountain Capital Ltd (“Company,” “we,” “us” or “our”). This Privacy Notice applies solely to residents of the State of California (“CA Users”). We adopt this Privacy Notice in compliance with the California Consumer Privacy Act of 2018 (“CCPA”) and other applicable California State privacy laws. Any terms defined in the CCPA have the same meaning when used in this Privacy Notice. CA Users with disabilities who wish to access this Privacy Notice in an alternative format can contact us by calling us at: +1 970 286-5572; emailing us at: ; or sending us U.S. mail to our US headquarters at: 40 Gates St, Boston, MA 02127, USA.

Categories of Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular CA User or device (“personal information”). In particular, we have collected the following categories of personal information from CA Users within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone number or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, postal address, telephone number, passport number, driver's license or State identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status or genetic information (including familial genetic information).	YES
F. Internet or other similar network activity.	Browsing history, search history, information on a CA User's interaction with a Website, application or advertisement.	NO

Personal information does not include:

Publicly available information from government records.
De-identified or aggregated CA User information.
Information excluded from the CCPA's scope, such as:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information for which we indicated “YES” above from the following categories of sources:

Directly from our CA Users. For example, from online registration forms that our CA Users submit to us related to the products and/or services that we (and our third-party service providers) offer by and through the Website.
Indirectly from our CA Users. For example, through information we collect from our CA Users in the course of providing our products and/or services to them.
Directly and indirectly from activity on the Website. This includes the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet Service Provider. In addition, we obtain certain Website usage details and analytics as the same are collected automatically by us and our third-party partners.
From surveys and other questionnaires that we ask CA Users to complete.
From third parties that interact with us in connection with the products and/or services that we offer to our CA Users.

Use of Personal Information

We may use or disclose the personal information that we collect for one or more of the following business purposes:

To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in connection with your request for information regarding specific services, as well as information regarding the other products and/or services featured on the Website, we will use that personal information to better provide you with the requested information.
To provide you with information, products, or services that you request from us.
To create, maintain, customize, and secure your account with us.
To provide you with e-mail, direct mail and telemarketing messages concerning certain Company products and/or services, as well as third-party products and/or services, that we believe may be of interest to you.
To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Website’s Terms and Conditions.
To improve the Website and better present its contents to you.
For customer service purposes and to respond to inquiries from you.
For testing, research, analysis and product development.
As necessary or appropriate to protect our rights, property or safety, and that of our clients or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred.

We 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 with notice.

Sharing Personal Information

We do not sell or share personal information about our current, former, or potential customers. The only exceptions may be when this information is required by a legal institution or permitted or instructed directly by the customer or consumer.

Also, please note, we do not collect information from CA Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of CA Users that we actually know are less than eighteen (18) years of age. Without limiting the foregoing, we have not shared or sold the personal information of CA Users that we actually know are less than sixteen (16) years of age in the preceding twelve (12) months.

Your Rights and Choices

The CCPA provides CA Users (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable CA User request, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we have shared that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).

Deletion

Request Rights You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable CA User request, we will delete (and direct our service providers to delete) your personal information from our (their) records, unless an exception applies; provided, however, that in some cases, strictly for regulatory compliance purposes and to better evidence/honor opt-out/unsubscribe requests (and for no other purposes), we may retain certain items of your personal information on a de-identified and aggregated basis in such a manner that the data no longer identifies you.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our obligations in connection with our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech rights, ensure the right of another CA User to exercise their free speech rights or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with CA User expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability and Deletion Rights

To exercise your access, data portability and/or deletion rights described above, please submit a verifiable CA User request to us by either:

Emailing us at: ; or
Sending us U.S. mail to: "MoneySmartUSA": 40 Gates St, Boston, MA 02127, USA.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information.

You may only make a verifiable CA User request for access or data portability twice within a 12-month period. The verifiable CA User request must:

Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Making a verifiable CA User request does not require you to create an account with us. We will only use personal information provided in a verifiable CA User request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to all verifiable CA User requests within forty-five (45) days of the receipt thereof. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable CA User 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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you with a different level or quality of goods or services; and/or
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to this Privacy Notice

We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will notify you by email or through a notice on the Website’s homepage.

Contact Information

If you have any questions or comments about this Privacy Notice, our Privacy Policy, the ways in which we collect and use 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 by either:

Emailing us at: ; or
Sending us U.S. mail to "MoneySmartUSA": 40 Gates St, Boston, MA 02127, USA