Privacy policy

• The date and time (with time zone) of a website visit. the Internet and allows communications with other computers to send it content and other information.
• Internet Protocol (IP) address.  A computer’s IP address establishes its location on
• Type of Internet traffic associated with a specific IP address;
• Type of Internet traffic associated with a specific time or event;
• Type of technology used to access the Site (such as the type of internet browser and type of operating system);
• Types of events;
• The location associated with an event (such as apparent nation of origin);
• Host names; and
• Malicious software identification.

We use the above information to measure the number of visitors to the different sections of the Site, assess system performance and to help us make the Site more useful to our visitors.  To remediate computer security incidents, such data may be manually analyzed to allow computer security specialists to identify Internet Service Providers (ISPs) and, in extreme cases, to attempt to identify the specific computer and individual involved in an attack on the Site.

• Scope
  When we use the term "personal information" in this California Privacy Policy, we are referring to 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 (i.e., a California resident) or household.
  For purposes of this California Privacy Policy, personal information does not include:Publicly available information from government records;Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you; andInformation excluded from the CCPA's scope, such as health or medication information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA); or information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), or the Gramm-Leach-Bliley Act (GLBA) (e.g., information concerning Fillmore investors).
• Collection and Use of Personal Information
  We collect personal information from and about you for a variety of purposes. For example, we use personal information: (i)To provide and manage products and services to you or an entity with which you are affiliated; (ii)To communicate with you; (iii)For marketing purposes; (iv)To monitor questions and transactions to ensure service quality, compliance with procedures, and to combat fraud; and (v)To protect the security and integrity of our business, comply with legal and regulatory requirements and obligations, and as otherwise permitted or required by law.
  In the last 12 months, we may have collected the following categories of personal information:

Category of Personal Information Collected	Collected?	Source of Collection
Identifiers, such as your name, address, email address, SSN, driver’s license number, passport number, or other similar identifiers.	Yes	Directly from you (for instance, some users provide us with their email address in order to receive marketing from us).Via website activity (for instance, we may collect an IP address via our cookies). From business partners or other third parties (for instance, in order to obtain contact details).From institutional clients (for instance, to fulfill certain due diligence requirements).
California Customer Records (Cal. Civ. Code § 1798.80(e)), such as birthdate, contact information and payment information.	Yes	Directly from consumers (for instance, some users provide us with their email address in order to receive marketing from us).Via website activity (for instance, we may collect an IP address via our cookies). Please see our Cookies Policy for more details). From business partners or other third parties (for instance, in order to obtain contact details). From client representative (for instance to fulfill due diligence requirements).
Protected Classification Characteristics, such as age, race, religion or creed, marital status, medical condition, gender, sexual orientation, veteran or military status, genetic information, etc.	Yes	From business partners -although not collected systematically, there are instances where we may obtain this information (e.g., for instance, business contacts may share details such as an upcoming marriage or birth of a child with our personnel).
Commercial information, such as services purchased, obtained.	Yes	From consumers or third parties (e.g., information about a financial intermediary's or client representative's business transactions with Fillmore and other managers)
Biometric information, such as face, eye or other biometric scans.	No
Internet or similar network activity, such as device information, logs and analytics data.	Yes	Via website activity (for instance, our cookies may give us information regarding how consumers interact with our website).
Geolocation data, such as approximate location information from your device or generated based on IP address.	Yes	Via website activity (for instance, our cookies may give us information regarding how consumers interact with our website).
Sensory data, such as recordings of phone calls with us, where permitted by law.	Yes	Directly from you
Professional or employment- related information, such as previous contact details or your employment history (applicants only)	Yes	Directly from youFrom business partners or other third parties (for instance, as it may relate to past contact details).For applicants, from third parties you direct to share information with us.
Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99), such as educational history, degree (for applicants)	Yes	Directly from youThird parties you direct to share information with us.
CellInferences, such as predictions about your interests and preferences.	Yes	Via website activity (for example, in certain instances a user’s behavior on our website may be associated with an email address if the user has arrived at our website via our email marketing. The association of website behavior with a user profile is for Fillmore internal use only and never shared with third parties).

Sensitive Personal Information
‍Some of the personal information described in the “Category of Personal Information” table above also constitutes “Sensitive Personal Information” under the CA privacy laws. We use and disclose Sensitive Personal Information for business and compliance functions and for legally authorized purposes. We currently do not collect or use Sensitive Personal Information for the purpose of inferring characteristics about consumers.Categories of Sensitive Personal Information which we collect and use:

(i)Government-issued Identifiers: Social Security Number, driver’s license, state id card or passport number;

(ii)Account log-in credentials: (usernames with password, access code or other credential that permits access to an account) allowing access to your account for our digital offerings. This information would be sourced directly from you and does not relate to financial accounts;

(iii)Non-publicly available information about racial or ethnic origin, religious or philosophical beliefs, or union membership; and (iv)Non-publicly available health information and sexual orientation information.

• Data Retention Period
  Fillmore will retain records (hardcopy and electronic) that are legally required to be maintained. Generally, Fillmore will maintain these records, or cause them to be maintained, for at least the minimum period required. Records that are required to be maintained by more than one applicable law and/or under differing storage requirements will be maintained for the longest retention period and in accordance with the most restrictive storage standard.
• Disclosure of Personal Information
  We may share personal information with third parties for a business purpose including delivering online advertisements to you on your devices and tailoring those ads to your interests. Whenever we disclose personal information to a third party, we enter into a contract that: (i)prevents or limits the ability of the third party to further share the information with other entities and requires the third party to keep the information confidential, (ii)contains all required obligations as well as appropriate data protection practices as prescribed by the CA privacy laws.
  In the past 12 months, Fillmore may have shared the following categories of personal information to third parties for a business purpose: (i)Identifiers (ii)Personal Information categories listed in the California Customer Records statute.
  Fillmore does not sell your personal information. As previously mentioned, in some instances Fillmore may share personal information with third parties. However, these instances are either not a “sale” of information under the CA privacy laws or qualify for an exemption to the definition of “sell” (such as providing information to a third party for a specific purpose).
• Your Rights Under CA Privacy Laws
  As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations):

The Right to Know	Directly from you (for instance, some users provide us with their email address in order to receive marketing from us).Via website activity (for instance, we may collect an IP address via our cookies). From business partners or other third parties (for instance, in order to obtain contact details).From institutional clients (for instance, to fulfill certain due diligence requirements).
The Right to Request Deletion	Directly from consumers (for instance, some users provide us with their email address in order to receive marketing from us).Via website activity (for instance, we may collect an IP address via our cookies). Please see our Cookies Policy for more details). From business partners or other third parties (for instance, in order to obtain contact details). From client representative (for instance to fulfill due diligence requirements).
The Right to Correct Inaccurate Personal Information	You have the right to request the correction of inaccurate personal information.
The Right to Limit Use and Disclosure of Sensitive Personal Information	We currently limit our uses and disclosure of Sensitive Personal Information only to those purposes permissible under CA privacy laws as described above in the “Collection and Use of Personal Information” section of this California Privacy Policy. We currently do not collect or use Sensitive Personal Information for the purpose of inferring characteristics about consumers and therefore do not offer a right to limit our use and disclosure of your Sensitive Personal Information. In the event our practices change, we will update this California Privacy Policy and provide you with an option to limit our use and disclosure of your Sensitive Personal Information.
The Right to Opt Out of Personal Information Sale/Sharing	You have the right to direct us not to sell or share personal information we have collected about you to third parties now or in the future.
The Right to Non-Discrimination	Via website activity (for instance, our cookies may give us information regarding how consumers interact with our website).

• To Exercise Your Rights Under the CA Privacy Laws
  To exercise your rights under the CA privacy laws, please contact Fillmore by either emailing <INSERT EMAIL ADDRESS> or calling 614-781-1420.
  When we receive a request, we will attempt to verify the requestor’s identity both as a California resident and by associating the identity with personal information previously collected. As such, the request must provide us with enough information that we can reasonably identify and verify that you are the person about whom we collected personal information. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
  You may make requests on behalf of your minor children. You may also register another person with the California Secretary of State in order to authorize that person to act on your behalf.
  We will attempt to respond to all verifiable consumer requests within 45 days. In the event we need more time to respond to a request, the CA privacy laws allow for an additional 45 days extension. We will notify you within the first 45-day period if we will need to extend the time to respond.
• Contact Us
  If you have any questions or requests in connection with this California Privacy Policy or other privacy-related matters, please send an email to info@fillmorecap.com or call us at 415-834-1476.