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California Privacy PolicyCalifornia Privacy Policy


Arcus Financial Intelligence Inc.
Privacy Policy for California ResidentsArcus Financial Intelligence Inc.
Privacy Policy for California Residents

This Policy for California Residents supplements the information contained in Arcus's Privacy Policy (US) and applies solely to all users and others who reside in the State of California ("California consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this CCPA Policy.

This Policy for California Residents supplements the information contained in Arcus's Privacy Policy (US) and applies solely to all users and others who reside in the State of California ("California consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this CCPA Policy.

Information We CollectInformation We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (" personal information "). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
In particular, we collect the following categories of personal information from California consumers within the last twelve (12) months:

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (" personal information "). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
In particular, we collect the following categories of personal information from California consumers within the last twelve (12) months:

CategoryCategoryExamplesExamplesCollectedCollected
A. Identifiers.A. Identifiers.A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.YESYES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).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, 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.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. Some personal information included in this category may overlap with other categories.YESYES
C. Protected classification characteristics under California or federal law.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, genetic information (including familial genetic information).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, genetic information (including familial genetic information).YES (age only)YES (age only)
D. Commercial information.D. Commercial information.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.YESYES
E. Biometric information.E. 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.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.NONO
F. Internet or other similar network activity.F. Internet or other similar network activity.Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.NONO
G. Geolocation data.G. Geolocation data.Physical location or movements. Physical location or movements. NONO
H. Sensory data.H. Sensory data.Audio, electronic, visual, thermal, olfactory, or similar information.Audio, electronic, visual, thermal, olfactory, or similar information.NONO
I. Professional or employment-related information.I. Professional or employment-related information.Current or past job history or performance evaluations.Current or past job history or performance evaluations.NONO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).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. 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. NONO
K. Inferences drawn from other personal information.K. Inferences drawn from other personal information.Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.NONO


We obtain the categories of personal information listed above indirectly, from companies you contract with for financial services, under consent that you provide to those companies.We obtain the categories of personal information listed above indirectly, from companies you contract with for financial services, under consent that you provide to those companies.

Use of Personal InformationUse of Personal Information

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

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to facilitate a bill payment transaction, we will use that information to process your payment and facilitate the transaction.
  • To process your requests, transactions, and payments and prevent money laundering and fraud.
  • To provide support and to respond to inquiries related to services you have requested.
  • For testing, research, analysis, and product development, including to develop and improve our products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • 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 about California consumers is among the assets transferred.
  • Or as otherwise set forth in the CCPA.
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 notice.We may use or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to facilitate a bill payment transaction, we will use that information to process your payment and facilitate the transaction.
  • To process your requests, transactions, and payments and prevent money laundering and fraud.
  • To provide support and to respond to inquiries related to services you have requested.
  • For testing, research, analysis, and product development, including to develop and improve our products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • 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 about California consumers is among the assets transferred.
  • Or as otherwise set forth in the CCPA.
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 notice.

Sharing Personal InformationSharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Arcus has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell personal information. Arcus has not sold personal information to any third parties.We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Arcus has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell personal information. Arcus has not sold personal information to any third parties.

Personal Information CategoryPersonal Information CategoryCategory of Third-Party RecipientsCategory of Third-Party Recipients
Business Purpose DisclosuresBusiness Purpose DisclosuresSalesSales
A: Identifiers.A: Identifiers.To facilitate the offering of our financial management products which include bill payments and financial data exchange.  For example, to effect bill payments to an account you designate, or provide a third party that you engage with balance and transaction history of your account.To facilitate the offering of our financial management products which include bill payments and financial data exchange.  For example, to effect bill payments to an account you designate, or provide a third party that you engage with balance and transaction history of your account.None.None.
B: California Customer Records personal information categories.B: California Customer Records personal information categories. To facilitate the offering of our financial management products which include bill payments and financial data exchange.  For example, to effect bill payments to an account you designate, or provide a third party that you engage with balance and transaction history of your account. To facilitate the offering of our financial management products which include bill payments and financial data exchange.  For example, to effect bill payments to an account you designate, or provide a third party that you engage with balance and transaction history of your account.None.None.
C: Protected classification characteristics under California or federal law.C: Protected classification characteristics under California or federal law.To facilitate the offering of our financial management products which include bill payments and financial data exchange.  For example, to effect bill payments to an account you designate, or provide a third party that you engage with balance and transaction history of your account.To facilitate the offering of our financial management products which include bill payments and financial data exchange.  For example, to effect bill payments to an account you designate, or provide a third party that you engage with balance and transaction history of your account.None.None.
D: Commercial information.D: Commercial information.To facilitate the offering of our financial management products which include bill payments and financial data exchange.  For example, to effect bill payments to an account you designate, or provide a third party that you engage with balance and transaction history of your account.To facilitate the offering of our financial management products which include bill payments and financial data exchange.  For example, to effect bill payments to an account you designate, or provide a third party that you engage with balance and transaction history of your account.None.None.
E: Biometric information.E: Biometric information.None.None.None.None.
F: Internet or other similar network activity.F: Internet or other similar network activity.None.None.None.None.
G: Geolocation data.G: Geolocation data.None.None.None.None.
H: Sensory data.H: Sensory data.None.None.None.None.
I: Professional or employment-related information.I: Professional or employment-related information.None.None.None.None.
J: Non-public education information.J: Non-public education information.None.None.None.None.
K: Inferences drawn from other personal information.K: Inferences drawn from other personal information.None.None.None.None.


Your Rights and ChoicesYour Rights and Choices

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

Right to Know and Data PortabilityRight to Know and Data Portability

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 (the "right to know"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete ), 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 share that personal information.
If we disclosed your personal information for a business purpose, a list of such disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

  • The specific pieces of personal information we collected about you (also called a data portability request).
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 (the "right to know"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete ), 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 share that personal information.
If we disclosed your personal information for a business purpose, a list of such disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

  • The specific pieces of personal information we collected about you (also called a data portability request).
Right to DeleteRight to Delete

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 (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete ), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, take actions reasonably anticipated within the context of our ongoing business relationship with the third party whom you consented to provide your information to us, or otherwise perform our contract with such third party.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq. ).
  6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and with the third party to whom you consented to share your information with us.
  7. Comply with a legal obligation.
  8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

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 (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete ), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, take actions reasonably anticipated within the context of our ongoing business relationship with the third party whom you consented to provide your information to us, or otherwise perform our contract with such third party.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq. ).
  6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and with the third party to whom you consented to share your information with us.
  7. Comply with a legal obligation.
  8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or DeleteExercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by:

  • Emailing us at contact@arcusfi.com.
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
    • First verifying yourself through the third party that originally shared your information with us.
    • Providing identifying information that we verify to match that we have received.
  • 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.

We will only use personal information provided in the request to verify the requestor's identity or authority to make it.To exercise your rights to know or delete described above, please submit a request by:

  • Emailing us at contact@arcusfi.com.
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
    • First verifying yourself through the third party that originally shared your information with us.
    • Providing identifying information that we verify to match that we have received.
  • 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.

We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

Response Timing and FormatResponse Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact privacy_contact@arcusfi.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 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 12-month period preceding our receipt of your request. 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. 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 services.
  • Charge you different prices or impose penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for services or a different level or quality of goods or services.
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact privacy_contact@arcusfi.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 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 12-month period preceding our receipt of your request. 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. 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 services.
  • Charge you different prices or impose penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for services or a different level or quality of goods or services.
Non-DiscriminationNon-Discrimination

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

  • Deny you services.
  • Charge you different prices or impose penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for services or a different level or quality of goods or services.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you services.
  • Charge you different prices or impose penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for services or a different level or quality of goods or services.