Privacy Policy

PRIVACY POLICY

 

Last Updated and Effective Date: October 23, 2023

 

This Privacy Policy describes how Auxilior Capital Partners, Inc., Auxilior Capital Partners Canada, ULC, and our subsidiaries and affiliated companies (collectively, “Auxilior,” “we,” or “us”) handle your personal information and your data privacy rights. Personal information is sometimes also referred to as personal data, personally identifiable information or other like terms to mean any information that directly or indirectly identifies you or is reasonably capable of being associated with you or your household. This Privacy Policy applies to personal information we collect online and offline, such as when you inquire about our services, including financing and leasing solutions, conduct business dealings with us, or when you otherwise interact with us (collectively, “Services”). We may provide different or additional notices of our privacy practices with respect to other personal information collection practices not within the scope of this Privacy Policy, such as if you apply for a job at Auxilior, in which case this Privacy Policy will not apply.

 

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. We may also provide you with an additional notice (such as by adding a statement to the Services or sending you a notification), in connection with making material changes to this Privacy Policy. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you. By using our Services you consent to all collection and uses of personal information as set out in this Privacy Policy.

 

 

I.	NOTICE AT COLLECTION			3
	A.	Collection of Personal Information		3
		1.  Personal Information You Provide to Us		3
		2.  Personal Information We Collect Automatically		3
		3.  Personal Information We Collect From Other Sources		4
		4.  Personal Information We Derive		4
	B.	Purpose and Use of Personal Information		4
	C.	Disclosure of Personal Information		5
	D.	Retention of Personal Information		5
II.	ANALYTICS			5
III.	YOUR CHOICES			6
	A.	Account Information		6
	B.	Cookies		6
IV.	TRANSFER OF PERSONAL INFORMATION TO THE UNITED STATES			6
V.	CHILDREN			6
VI.	OUR CALIFORNIA RIGHTS			7
	A.	Summary of Categories of Personal Information Collected and Disclosed		7
	B.	Selling or Sharing of Personal Information		11
	C.	Sensitive Personal Information		12
	D.	Your Privacy Rights		12
	E.	Instructions on How to Exercise Your Privacy Rights		13
	F.	Authorized Agents		13
	G.	Additional Disclosure for California Residents		13
	H.	Do Not Track		13
VII.	CONTACT US			13

 

 
I. NOTICE AT COLLECTION

A.    Collection of Personal Information
We describe below the personal information we collect, source of collection, how we use your personal information, our personal information disclosure practices, our retention of personal information, and other relevant information.

 

1. Personal Information You Provide to Us

We collect personal information you provide directly to us when you engage our Services. The types of personal information that we may collect directly from you include: (a) identifiers, such as name, email address, address, phone number, unique personal identifier, Internet Protocol address, online identifier, account name, social security/tax identification number, driver’s license number, passport number, state identification, or other similar identifiers; (b) characteristics about you, such as gender, age, language, and physical description; (c) financial information, such as information about your loan, property, credit score or reports, income, credit card and bank account information, financial transaction history, account and loan numbers, and other similar information; (d) commercial information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; (e) Internet or other electronic network activity information, such as IP address and device information; (f) geolocation data, such as address; and (g) professional or employment information, such as job title.

 

Some of the information we collect may be considered sensitive personal information, such as: (a) social security, social insurance number, driver’s license, state identification card, government-issued identification card, or passport number; (b) account log-in, financial account and other like information; and (c) precise geolocation.

 

2. Personal Information We Collect Automatically

We automatically collect certain personal information about your interactions with us or our Services. We may collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services.

 

We and others that control collection of personal information may use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we may use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness.

 

We do not use cookies and other technologies to collect your personal information.

 

3. Personal Information We Collect From Other Sources

We may collect the above personal information from third party sources, such as entities we engage to assist us with providing the Services.

 

4. Personal Information We Derive

We may derive personal information or draw inferences about you based on the information we collect.

 

B.    Purpose and Use of Personal Information

We may use the categories of personal information identified in Collection of Personal Information in Section I.A above for the following purposes:

 

• Provide, maintain, and improve our Services;
• Conduct business dealings with our customers, service providers or contractors;
• Process financial transactions for our customers as part of providing the Services;
• For our accounting, financial, tax and other business-related operations;
• Personalize and improve your experience on our Services;
• Send you technical notices, security alerts, and support and administrative messages;
• Respond to your comments and questions and provide customer service;
• Communicate with you about products, services, and events offered by Auxilior and others and provide news and information that we think will interest you;
• Monitor and analyze trends, usage, and activities in connection with our Services;
• Advertising, marketing, and sales purposes;
• Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Auxilior and others;
• Debug to identify and repair errors in our Services;
• Comply with our legal and financial obligations; and
• Carry out any other purpose described to you at the time the information was collected.

 

C.    Disclosure of Personal Information

 

We may disclose personal information in the following circumstances or as otherwise described in this Privacy Policy:

 

• Our Service Providers and Contractors: We may disclose your personal information to service providers and contractors who assist us with assessing qualification for financing, financial and tax management, cloud storage, email communications, security, IT and technical services, sales, and customer service.
• Legal Disclosures: We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. We may also disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Auxilior, our users, the public, or others.
• Disclosed to Advisors and Lawyers: We may disclose personal information to our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• Disclosed During Change of Ownership: We may disclose personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Among Our Family of Companies: Personal information may be disclosed between and among Auxilior and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
• With Your Consent: We may disclose personal information with your consent or at your direction.

 

D.    Retention of Personal Information

We store personal information pursuant to our retention schedule, which requires us to maintain personal information for as long as necessary to carry out the purposes for which we originally collected the personal information and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. For example, we may retain certain accounting and finance-related information for three to seven years, legal and regulatory-related information for seven to ten years, and emails for one year.

 

II.    ANALYTICS
We allow others to provide analytics services on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, and links clicked. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.

 

III.    YOUR CHOICES

 

A.    Account Information
You may update and correct certain account information at any time by emailing us at customerservice@servicehqtrs.com, or calling us at 1-877-773-0333. If you wish to delete your account, please email or call us, but note that we may retain certain information as required by law or for our legitimate business purposes.

Upon your request we will provide you with details regarding the personal information we have collected from you and the categories of Auxilior employees who have access to that information within the Auxilior organization.

You may withdraw consent to the dissemination or use of the personal information collected from you by providing a written request to our Privacy Officer, and that request will be addressed in accordance with applicable privacy laws.

 

B.    Cookies
Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

 

IV.  TRANSFER OF PERSONAL INFORMATION TO THE UNITED STATES
Auxilior is headquartered in the United States, and we have operations and service providers in the United States and Canada. Therefore, we and our service providers may transfer your personal information inter-country, inter-state and/or inter-provincially. Due to such transfers we and our services providers may store or access your personal information in jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

 
V. CHILDREN
This website is not intended for or directed at children under the age of 18. In addition, we do not knowingly collect personal information from children under the age of 18. We also do not knowingly sell, share, use for targeted advertising or disclose the personal information of children under the age of 18.

 

VI. OUR CALIFORNIA RIGHTS
The California Privacy Rights Act or “CPRA” (Cal. Civ. Code § 1798.100 et seq.) and the Shine the Light law (Cal. Civ. Code § 1798.83) afford consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.

 

A.  Summary of Categories of Personal Information Collected and Disclosed

In the preceding 12 months, we have collected the categories of personal information set forth in the table below. For details about the precise data points we collect and the categories of sources of such collection, please see Collection of Personal Information in Section I.A above. We collect personal information for the business and commercial purposes described in Purpose and Use of Personal Information in Section I.B above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients, which we also describe in greater detail in Disclosure of Personal Information in Section I.C above:

 

Category of Personal Information We Collect	Business Purpose for Disclosure	Category of Recipients
Identifiers, such as name, email address, address, phone number, unique personal identifier, Internet Protocol address, online identifier, account name, social security/tax identification number, driver’s license number, passport number, state identification, or other similar identifiers	Provide our Services; Communicate with you; Comply with our legal and financial obligations; For security and technical reasons; and For other purposes described in Disclosure of Personal Information in Section I.C above.	·       Service providers and contractors, such as financing, financial and tax management, cloud storage, email communications, security, IT and technical services, sales, and customer service vendors; and ·       To other parties described in Disclosure of Personal Information in Section I.C above.
Any personal information described in the California Customer Records Act (Cal. Civ. Code § 1798.80(e)), such as name, social security number, address, telephone number, passport number, driver’s license or state identification card number, employment, bank account number, credit card number, debit card number, or any other financial information.	Provide our Services; Communicate with you; Comply with our legal and financial obligations; For security and technical reasons; and For other purposes described in Disclosure of Personal Information in Section I.C above.	·       Service providers and contractors, such as financing, financial and tax management, cloud storage, email communications, security, IT and technical services, sales, and customer service vendors; and ·       To other parties described in Disclosure of Personal Information in Section I.C above.
Characteristics of protected classifications under California or federal law, such as gender and age.	Provide our Services; Communicate with you; Comply with our legal and financial obligations; For security and technical reasons; and For other purposes described in Disclosure of Personal Information in Section I.C above.	·       Service providers and contractors, such as financing, financial and tax management, cloud storage, email communications, security, IT and technical services, sales, and customer service vendors; and ·       To other parties described in Disclosure of Personal Information in Section I.C above.
Commercial information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Provide our Services; Communicate with you; Comply with our legal and financial obligations; For security and technical reasons; and For other purposes described in Disclosure of Personal Information in Section I.C above.	·       Service providers and contractors, such as financing, financial and tax management, cloud storage, email communications, security, IT and technical services, sales, and customer service vendors; and ·       To other parties described in Disclosure of Personal Information in Section I.C above.
Internet or other electronic network activity information.	Provide our Services; Communicate with you; Comply with our legal and financial obligations; For security and technical reasons; and For other purposes described in Disclosure of Personal Information in Section I.C above.	·       Service providers and contractors, such as financing, financial and tax management, cloud storage, email communications, security, IT and technical services, sales, and customer service vendors; and ·       To other parties described in Disclosure of Personal Information in Section I.C above.
Geolocation data, such as address.	Provide our Services; Communicate with you; Comply with our legal and financial obligations; For security and technical reasons; and For other purposes described in Disclosure of Personal Information in Section I.C above.	·       Service providers and contractors, such as financing, financial and tax management, cloud storage, email communications, security, IT and technical services, sales, and customer service vendors; and ·       To other parties described in Disclosure of Personal Information in Section I.C above.
Professional or employment-related information, such as job title.	Provide our Services; Communicate with you; Comply with our legal and financial obligations; For security and technical reasons; and For other purposes described in Disclosure of Personal Information in Section I.C above.	·       Service providers and contractors, such as financing, financial and tax management, cloud storage, email communications, security, IT and technical services, sales, and customer service vendors; and ·       To other parties described in Disclosure of Personal Information in Section I.C above.
Inferences drawn from any of the information identified herein, such as preferences and characteristics.	Provide our Services; Communicate with you; Comply with our legal and financial obligations; For security and technical reasons; and For other purposes described in Disclosure of Personal Information in Section I.C above.	·       Service providers and contractors, such as financing, financial and tax management, cloud storage, email communications, security, IT and technical services, sales, and customer service vendors; and ·       To other parties described in Disclosure of Personal Information in Section I.C above.
Sensitive personal information, such as social security, driver’s license, state identification card, or passport number; account log-in; financial account, debit card, or credit card number and other like information; precise geolocation; and race and ethnicity.	Provide our Services; Communicate with you; Comply with our legal and financial obligations; For security and technical reasons; and For other purposes described in Disclosure of Personal Information in Section I.C above.	·       Service providers and contractors, such as financing, financial and tax management, cloud storage, email communications, security, IT and technical services, sales, and customer service vendors; and ·       To other parties described in Disclosure of Personal Information in Section I.C above.

 

Our prior 12-month personal information handling practices are consistent with our current personal information handling practices described in NOTICE AT COLLECTION in Section I.

 

B. Selling or Sharing of Personal Information
We do not sell your personal information or share your personal information for cross-context behavioral advertising, and have not done so in the prior 12 months. We also do not knowingly sell or share the personal information of children under the age of 16, and have not done so in the prior 12 months.

 

C. Sensitive Personal Information
Under the CPRA, certain types of personal information are considered “sensitive” personal information and require additional data privacy rights and obligations. Auxilior collects social security, driver’s license, state identification card, or passport number; account log-in; financial account, and other like information; and precise geolocation; which may be considered sensitive personal information under the CPRA. We only collect this sensitive personal information to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services and to perform services on behalf of the business (“Permitted Uses”). Because Auxilior uses this sensitive personal information for Permitted Uses, there is no need for it to provide a Limit Use and Disclosure of Sensitive Personal Information right under the CPRA.

 

D. Your Privacy Rights
The CPRA affords consumers residing in California the following rights with respect to their personal information, subject to certain exceptions:

 

• (1) Right to Delete. You have the right to request us to delete the personal information we have collected about you.
• (2) Right to Correct. You have the right to request us to correct inaccurate personal information we maintain about you.
• (3) Right to Know and Access. You have the right to know and access the personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
• (4) Right to Data Portability. You have the right to receive the information under right (3) in a format, to the extent technically feasible, that is portable, usable, and allows you to transmit the personal information to a person without impediment.
• (5) Rights Related to Sharing for Cross-Context Behavioral Advertising or Sale. We do not share your personal information for cross-context behavioral advertising or sell your personal information. Please Contact Us in Section VII below if you have any questions.”
• (6) Rights Related to Sensitive Personal Information. The CPRA provides additional protection for sensitive personal information. Please see Sensitive Personal Information in Section VI.C above for more information.
• (7) Right to No Discrimination. You have the right not to be discriminated against for exercising any of your privacy rights. This includes us not: (a) denying you goods or services; (b) charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (c) providing you a different level or quality of goods or services; (d) suggesting to you that you will receive a different price or rate for goods or services or a different level or quality of goods or services; and (e) retaliating against you for exercising your privacy rights.

E. Instructions on How to Exercise Your Privacy Rights
You may exercise your privacy rights by calling our toll-free phone number at 1-877-773-0333 or emailing us at customerservice@servicehqtrs.com. In some instances, we will need to verify your identity before honoring your privacy right request. We will verify your identity by asking you to provide personal information related to your recent interactions with us. We will honor your privacy rights request within 45 calendar days of receipt, unless we request an extension under the CPRA.

 

F. Authorized Agents
If permitted by law, you may exercise your privacy rights through an authorized agent. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please Contact Us below in Section VII.

 

G. Additional Disclosure for California Residents
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at 1-877-773-0333 or customerservice@servicehqtrs.com.

 

H. Do Not Track
Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the websites you visit indicating that you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the do not track signal, we currently do not respond to the browser do not track signals.

 

VII. CONTACT US
If you have any questions about this Privacy Policy, please contact us at 1-877-773-0333 or customerservice@servicehqtrs.com. You may also contact the Company’s Privacy Officer at dverlizzo@auxcap.com or 1-877-773-0333.