We take our clients’ privacy very seriously. This disclosure is addressed to California residents only and concerns the practices of Qoru Capital, LLC (Qoru Capital) that relate to personal information of California residents. It explains what personal information we collect, where we collect it from, what we use it for, who we disclose it to, how long we keep it, the rights California residents may have, and how to exercise them. 

Please note that the CCPA, and this disclosure, do not apply to information covered by other federal and state privacy laws, including the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act and certain other laws.

INFORMATION WE COLLECT

Personal information categories listed in the California Customer Records Statute

Identifiers

In the past 12 months we have collected personal information (meaning information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with you or a household) in the following categories:

• A name;
• Signature;
• Social Security number;
• Physical characteristics or description;
• 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. 

NOTE: Some personal information included in this category may overlap with other categories.

Internet or other similar network activity

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Geolocation data

Physical location or movements.

Sensory data

Audio recordings of your contact with our customer service team.

Professional or employment-related information

Current or past job history or performance evaluations.

WHAT IS NOT COLLECTED:

Biometric information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Non-public education information

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Inferences drawn from other personal information

Audio, electronic, visual, thermal, olfactory, or similar information.

Personal Information DOES NOT Include:

• Publicly available information from federal, state, or local government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, such as 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 listed above from the following categories of sources:

• Directly from our customers or their agents. For example, from documents that our customers provide to us related to the services that we are asked to perform.
• Indirectly from our customers or their agents. For example, through information we collect from our customers in the course of providing services to them.
• Directly and indirectly from activity on our Website. For example, from submissions through our Website portal or Website usage details collected automatically.
• From third parties that interact with us in connection with the services we perform. For example, credit reporting agencies, appraisers, and other service providers.
• From our affiliates.

Use of Personal Information

We may use or disclose the personal information 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 personal information to apply for a loan, we will use that information to process your application, payment, and facilitate loan closing. We may also save your information for legal or regulatory purposes, loan fulfillment, and/or loan servicing.
• To provide, support, personalize, and develop our websites, products and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including investigating and addressing your concerns and to monitor and improve our response.
• To personalize your website experience and to deliver relevant content and product and service offerings, including targeted offers and other communications (with your consent, where required by law). To help maintain the safety, security, and integrity of our business websites, products and services, databases and other technology assets.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• 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 for other business purposes.
• To respond to audits or state or federal examinations by our regulators. 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

In the past 12 months, we have disclosed your personal information to a third party for a business purpose. We limit the information that we send service providers and require that our service providers only use shared personal information to perform the services requested in accordance with our Privacy Policy and have adequate security measures in place to protect any of your shared personal information.

We may share personal information with third parties:

• Such as vendors who provide employment verification, degree verification, title, document import, or other necessary services;
• Such as our subsidiary and affiliated businesses that provide quality services or products you may be interested in;
• For any purpose to which you expressly consent;
• To protect our rights or the rights or safety of others; and
• As may be required by law or regulation.

Sale of Personal Information

In the preceding 12 months, we have not sold to another business or any third party any personal information subject to the CCPA.

Retention of Personal Information

We take reasonable steps designed to ensure that your personal information is only processed for the minimum period necessary for the purposes set out in this disclosure. The criteria for determining the duration for which we will retain your personal information are as follows:

1. We will retain copies of your personal information in a form that permits identification only for as long as:
   1. We maintain an ongoing relationship with you (e.g., while you are still receiving services from us); or
   2. Your personal information is necessary in connection with purposes set out in this disclosure plus:
2. The duration of any applicable limitation period under applicable law; and where required by applicable law or a retention policy established in accordance with applicable law

In addition, if any relevant legal claims are anticipated/brought, we may continue to retain your personal information for such additional periods as are necessary in connection with that claim.

Once the periods above have concluded, each to the extent applicable or permitted by applicable law, we will 1) permanently delete or destroy the relevant personal information, or 2) archive your personal information so that it is beyond use; or 3) anonymize the relevant personal information.

Access to Information – Rights for California Residents

Unless your personal information is excluded from the scope of applicable laws, 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 12 months. Once we receive and confirm your verifiable consumer request, you have a right to know:

• The categories of personal information we have collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you.
• If we disclose your personal information for a business purpose, identifying the personal information that we collected.

Correction Requests Rights

Unless your personal information is excluded from the scope of applicable laws, you have the right to request that we correct any of your personal information that we collected from you and retained, subject to exceptions.

Deletion Requests Rights

Unless your personal information is excluded from the scope of applicable laws, you have the right to request that we delete any of your personal information that we collected from you and retained, subject to exceptions.

Please note that the Gramm-Leach-Bliley Act and the CCPA allow us to keep certain forms of data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. In addition, there may be certain data that we may not allow you to review for legal, security, or other reasons. 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 and take actions reasonably anticipated within the context of our ongoing business relationship with you.
• Perform a contract between us and 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, ensure the right of another consumer 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.).
• Enable solely internal uses that are reasonably aligned with consumer 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.

Opt-Out Right

You have the right to demand that we not sell your personal information, known as the right to opt out. The CCPA opts out consumers under age 16 by default, as they (or their legal parent or guardian) must affirmatively authorize personal information sales and may opt back out at any time.

Exercising Your Rights under the CCPA

If you are a California resident, you can submit a request to us by:

• Calling us at 954-444-2407 

• Emailing us at mikesimmons45@gmail.com 

Only you or an agent that you authorize to act on your behalf may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the California resident about whom we collected personal information or an authorized representative of such a resident.
• 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 the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Our practices with regard to verifying a request will vary depending on the request and the information we have on the person making the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically (provided we can do so securely). Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

Non-discrimination

You have the right to not receive discriminatory treatment for the exercise of the privacy rights conferred by the privacy laws of your state.

Information for Parents or Guardians

We do not knowingly collect or maintain information about children under the age of 16, unless that information is provided by a parent, legal guardian, or authorized adult.

Changes to this Privacy Notice

We reserve the right to update this Privacy Notice at any time to reflect changes in our business, legal or regulatory obligations. Any changes will be immediately effective upon the posting of the updated Privacy Notice.

Contact Information

If you have any questions or comments about this Privacy Notice or our privacy practices, please do not hesitate to contact us at:

• Phone: 954-444-2407 
• Email:  mikesimmons45@gmail.com 

Date of Last Review: December 20, 2024

Michael Simmons, Managing Member

NMLS ID: 892271