CCPA Rights Disclosure

Last updated November 23, 2022

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Sila Inc. (also referred to as Sila Money Inc., together with its subsidiaries and affiliates, “Sila”) maintains these CCPA Rights Disclosures (these “Disclosures”) to supplement the terms of the Website Privacy Statement at silamoney.com/legal/website-privacy-statement and the Sila Privacy Policy at silamoney.com/legal/sila-privacy-policy. These Disclosures apply to you only if you are an individual resident of the State of California.

These Disclosures provide you with additional information about how Sila collects, uses, discloses, and otherwise processes your personal information as a California resident within the scope of the California Consumer Privacy Act (“CCPA”) in relation to your use of the Website (as defined by Website Visitor Agreement at silamoney.com/legal/website-visitor-agreement) or the Services (as defined by the Sila Terms of Service at silamoney.com/legal/terms-of-service).

If you have any questions about these Disclosures, you may contact Sila at privacy@silamoney.com.

Sila reserves the right to change the provisions of this CCPA Rights Disclosure at any time and without providing notice to you. The date of the most recent version of these Disclosures will appear at the top of this page. Accordingly, you should visit this Disclosures page periodically to review its provisions and note any changes that may affect you.

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1. What is Personal Information?

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Under the CCPA and as used in these Disclosures, “Personal Information” means  information that identifies, relates to, or describes a particular consumer or household, or that is reasonably capable of being associated with or could be reasonably linked to, directly or indirectly, a particular consumer or household. Personal Information does not include any of the following: (i) publicly available information from government records; (ii) aggregated or anonymized data that is not capable of being associated with you; (iii) information related to job applicants, employees, contractors, or other Sila personnel; (iv) certain information that Sila, as a “service provider,” may process solely on behalf of its business customers; and (v) information covered by certain applicable sector-specific state or federal privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act (“GLBA”), the Driver’s Privacy Protection Act of 1994, and the California Financial Information Privacy Act.

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2. What Personal Information is Collected?

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Sila may collect from you or otherwise gather certain Personal Information about you in connection with your use of the Website or the Services. Please review the Website Privacy Statement and Sila Privacy Policy, as applicable, to learn more about the information Sila collects, including your Personal Information. To learn how to restrict the information Sila collects from your use of the Website, please refer to the Website Privacy Statement at silamoney.com/legal/website-privacy-statement. In the last 12 months, Sila has collected the following categories of Personal Information:

1. Individual Identifiers. Names, street addresses, email addresses, and other similar information that Sila may directly collect from you or indirectly collect by way of Sila’s partners or suppliers or other third parties you authorize to share information with Sila.‍
2. California Customer Records. Records identifying you, such as by your name, personal physical characteristics signature, telephone number, passport or other government identification number, education or employment history, and credit or other financial history, which Sila may directly collect from you or indirectly collect by way of Sila’s partners or suppliers or other third parties you authorize to share information with Sila.
3. ‍Other Professional Records. Business and employment records or other professional information, such as your current occupation, job title, employer, and industry, which Sila may directly collect from you or indirectly collect by way of Sila’s partners or suppliers or other third parties you authorize to share information with Sila.
4. ‍Commercial Information. Information about your or your company’s purchases or use of Sila’s products or services, which Sila may directly collect from you or indirectly collect by way of Sila’s partners or suppliers or other third parties you authorize to share information with Sila.
5. ‍Other Personal Information. Your Personal Information that may be identified as part of service requests to Sila or social media content and other public communications, which Sila may gather from public sources, directly collect from you, or indirectly collect by way of Sila’s partners or suppliers or other third parties you authorize to share information with Sila.
6. ‍Cookies and Other Network Information. Information generated from your use of the Website (pursuant to your authorized preferences) on browser and internet use, such as analytics data on your Website activity, which Sila may collect from your browser or device through use of cookies.
7. ‍Geolocation Data. Your general geographic location based on log data, which Sila may collect from your browser or device.
8. ‍Sensory Information. Notes, recordings (to which you have consented), or other data from phone calls, remote conferences, or virtual meetings, or any audio files, images, or video footage you choose to provide, any of which Sila may directly collect from you.

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3. How is Personal Information Used?

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Sila may use the Personal Information identified above as necessary in pursuit of the following business purposes: (i) providing or managing your access to the Services and any Website services, if and as applicable; (ii) auditing the transactions performed using the Services and managing Sila’s relationship with your or your company’s clients or platform users; (iii) communicating with you, such as by email, phone, push notifications, social media, or the Website; (iv) operating, evaluating, securing, enhancing, and improving Sila’s business, the Services, any Website services, and any other related products, services, or features; (v) recognizing you and remembering your information when you return to the Website or when you access or use the Services; (vi) curating and managing marketing campaigns and related business activities; (vii) debugging intended functionality of the Website or the Services; (viii) informing tests, training, research, analysis, and product development that supports the Website or the Services; (ix) preventing, detecting, and responding to system breaches or other security events; (x) defending, protecting, or enforcing Sila’s rights under any applicable agreements, terms, or conditions to which you or your company may have agreed; (xi) complying with legal process and any applicable legal or regulatory requirements; and (xii) fulfilling rights, enforcing obligations, and performing permitted activities within the scope of any applicable agreements, terms, or conditions Sila may have with you or your company.

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4. When is Personal Information Disclosed?

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In the last 12 months, Sila has not sold any Personal Information about you but may have disclosed Personal Information of any of the above categories to Sila’s partners or suppliers for a business purpose. While Sila never “sells” your Personal Information, Sila may occasionally disclose your Personal Information to certain of its partners or suppliers for business purposes as necessary to (i) assess and improve the Website or the Services, (ii) improving and measuring the success of advertising or marketing campaigns; (iii) detect, stop, and report fraudulent activities; or (iv) promote the products or services of Sila’s partners or suppliers and their associates in accordance with the GLBA. For more information on Sila’s disclosure practices as applied to information Sila obtains in connect with your use of the Website, please refer to the Website Privacy Statement, available at silamoney.com/legal/website-privacy-statement. For more information on Sila’s disclosure practices as applied to information Sila obtains in connection with your use of the Services, please refer to the Sila Privacy Policy at silamoney.com/legal/sila-privacy-policy.

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5. What Are Your Rights?

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As a California resident, you may be eligible to exercise any of the following rights in relation to the Personal Information that Sila collects, subject to certain limitations under applicable law:

1. The Right to Know. You have the right to request from Sila any or all of the following in relation to any Personal Information Sila may have collected about you or disclosed in the last 12 months: (i) the specific information or data points Sila has collected from or about you; (ii) the categories of Personal Information Sila has collected from or about you; (iii) the general sources of the Personal Information Sila has collected from or about you; (iv) the categories of Personal Information that Sila has disclosed about you to third parties for business purposes, as well as the types of third parties to whom Sila disclosed that Personal Information; (v) the categories of your Personal Information that Sila has sold (if any), and the types of third parties to whom Sila sold that Personal Information; or (vi) the business or commercial purposes for which Sila collected and used your Personal Information or, if applicable, sold your Personal Information. To exercise your right to know, please submit a written request to Sila by emailing privacy@silamoney.com with the subject “California Rights Request” and describing each of the above categories on which you are seeking information. Sila will need to verify your identity before it may process your request, such as by requiring you to log into your account or matching sufficient information provided by you with the information maintained in Sila’s systems (which may necessitate requesting additional Personal Information from you). Sila may in certain circumstances deny your request, particularly if Sila is unable to verify your identity.
2. ‍The Right to Request Deletion. You have the right to request deletion of Personal Information that we have collected from you, subject to certain exceptions, such as when Sila is providing or has provided Services to you or your company and Sila is required by law or internal policy to retain your Personal Information. To exercise your right to request deletion please submit a written request to Sila by emailing privacy@silamoney.com with the subject “California Rights Request” and identifying that you would like Sila to delete your Personal Information to the extent possible. Sila will need to verify your identity before it may process your request, such as by requiring you to log into your account or matching sufficient information provided by you with the information maintained in Sila’s systems (which may necessitate requesting additional Personal Information from you). Sila may in certain circumstances deny your request, particularly if Sila is unable to verify your identity.
3. ‍The Right to Opt Out of Information Sales. You have the right to request that Sila not sell your Personal Information to third parties, now or in the future. Although, as indicated above, Sila does not “sell” your Personal Information to any third parties, certain of Sila’s partners or suppliers may sell to third parties certain information that Sila discloses to them, such as your email address and aggregated or anonymized data. If, as a result of you exercising your right to know, Sila identifies third parties or types of third parties to whom Sila may have disclosed your Personal Information, then you should direct any requests exercising your right to opt out of information sales directly to those third parties.
4. ‍The Right to Non-Discrimination. You have the right not to be discriminated against in any way for exercising any of your other rights above.