THIS PRIVACY NOTICE FOR CALIFORNIA CONSUMERS (“NOTICE”), PROVIDED BY SMART PATH ASSIST (“SMART PATH ASSIST,” “COMPANY,” “WE,” OR “OUR”), SUPPLEMENTS, AND IS EXPRESSLY MADE PART OF, THE INFORMATION CONTAINED IN THE SMART PATH ASSIST ONLINE PRIVACY POLICY AND APPLIES SOLELY TO THOSE WHO ARE CONSUMERS (“YOU” OR “YOUR”) AS DEFINED IN SECTION 1798.140(G) OF THE CALIFORNIA CONSUMER PRIVACY ACT OF 2018 (“CCPA”). WE ADOPT THIS NOTICE IN COMPLIANCE WITH THE CCPA AND ANY TERMS DEFINED IN THE CCPA HAVE THE SAME MEANING WHEN USED IN THIS NOTICE.
SMART PATH ASSIST COLLECTS 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”). AS A CONSUMER, YOU HAVE CERTAIN RIGHTS REGARDING YOUR PERSONAL INFORMATION AS DEFINED IN THE CCPA. THIS NOTICE PROVIDES YOU WITH INFORMATION ON HOW SMART PATH ASSIST COLLECTS, USES, AND SHARES PERSONAL INFORMATION. IT ALSO OUTLINES THE RIGHTS YOU HAVE REGARDING PERSONAL INFORMATION THAT WE COLLECT FROM YOU AND DESCRIBES HOW YOU CAN EXERCISE THOSE RIGHTS.
Collection and Use of Personal Information
SMART PATH ASSIST RECOGNIZES THE ELEVEN (11) BROAD CATEGORIES OF PERSONAL INFORMATION REFERENCED IN THE CCPA THAT A BUSINESS MAY COLLECT ABOUT A CONSUMER. IN PARTICULAR, SMART PATH ASSIST HAS COLLECTED THE FOLLOWING CATEGORIES OF PERSONAL INFORMATION FROM CONSUMERS WITHIN THE LAST TWELVE (12) MONTHS:
Category
Examples
Collected
A. Identifiers.
A genuine name, alias, residential address, distinct personal identifier, online identifier, IP address, email address, account name, social security number, driver's license number, passport number, or comparable identifiers.
YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical traits or description, residential address, phone number, passport number, driver’s license or state ID card number, insurance policy details, educational background, employment status, work history, bank account details, credit card number, debit card number, or any other financial data, medical records, or health insurance particulars. Some personal details within this category may intersect with other categories.
YES
C. Protected classification characteristics under California or federal law.
Age (40 years or older), ethnicity, hue, lineage, birthplace, nationality, citizenship, faith or belief system, marital situation, health status, physical or mental incapacity, gender (including identity, expression, pregnancy or childbirth, and associated medical conditions), sexual orientation, military service or veteran status, hereditary data (including familial genetic data).
YES
D. Commercial information.
Documentation of personal belongings, items or services acquired, obtained, or contemplated, or other purchasing or consuming records or inclinations.
YES
E. Biometric information.
Genetic, physiological, behavioral, and biological attributes, or patterns of activity utilized to derive a template or other form of identifier or identifying information, such as fingerprints, facial features, vocal characteristics, iris or retina scans, typing patterns, walking patterns, or other physical traits, as well as data related to sleep, health, or exercise.
NO
F. Internet or other similar network activity.
Web browsing record, exploration record, details regarding a consumer's engagement with a website, app, or advertisement.
YES
G. Geolocation Data
Geographical whereabouts or mobility patterns.
NO
H. Sensory Data
AUDIO, ELECTRONIC, VISUAL, THERMAL, OLFACTORY, OR SIMILAR DATA.
NO
I. Professional or employment-related information.
CURRENT OR PRIOR EMPLOYMENT HISTORY OR PERFORMANCE ASSESSMENTS.
NO
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)).
EDUCATIONAL RECORDS DIRECTLY RELATED TO A STUDENT MAINTAINED BY AN EDUCATIONAL INSTITUTION OR PARTY ACTING ON ITS BEHALF, INCLUDING GRADES, TRANSCRIPTS, CLASS LISTS, STUDENT SCHEDULES, STUDENT IDENTIFICATION CODES, STUDENT FINANCIAL INFORMATION, OR STUDENT DISCIPLINARY RECORDS.
NO
K. Inferences drawn from other personal information.
PROFILE INDICATING A PERSON’S PREFERENCES, CHARACTERISTICS, PSYCHOLOGICAL TENDENCIES, INCLINATIONS, BEHAVIOR, ATTITUDES, INTELLIGENCE, ABILITIES, AND APTITUDES.
YES
AS A COMPANY ENGAGED IN FINANCIAL ACTIVITIES, SMART PATH ASSIST IS CLASSIFIED AS A “FINANCIAL INSTITUTION” UNDER THE GRAMM-LEACH-BLILEY ACT (“GLBA”). ALTHOUGH THE CCPA DOES NOT GRANT EXEMPTIONS TO FINANCIAL INSTITUTIONS, SECTION 1798.145(E) OF THE CCPA PROVIDES AN EXEMPTION FOR PERSONAL INFORMATION COLLECTED BY A FINANCIAL INSTITUTION IN ACCORDANCE WITH THE GLBA.
PERSONAL INFORMATION EXCLUDES PUBLICLY AVAILABLE INFORMATION FROM GOVERNMENT RECORDS, DE-IDENTIFIED OR AGGREGATED CONSUMER INFORMATION, OR INFORMATION OTHERWISE EXEMPT FROM THE CCPA’S SCOPE, SUCH AS INFORMATION COLLECTED IN ACCORDANCE WITH THE GLBA.
WE HAVE ACQUIRED THE CATEGORIES OF PERSONAL INFORMATION LISTED ABOVE FROM THE FOLLOWING SOURCES:
DIRECTLY FROM YOU. FOR INSTANCE, THROUGH FORMS YOU FILL OUT OR PRODUCTS AND SERVICES YOU ACQUIRE.
INDIRECTLY FROM YOU. FOR INSTANCE, THROUGH INFORMATION WE GATHER WHILE PROVIDING OUR SERVICES TO YOU, OR BY OBSERVING YOUR ACTIVITIES ON OUR WEBSITE.
FROM THIRD-PARTY BUSINESS PARTNERS INCLUDING, BUT NOT LIMITED TO, SOCIAL MEDIA PLATFORMS, ADVERTISING NETWORKS, AND ANALYTICS SERVICE PROVIDERS.
SMART PATH ASSIST MAY UTILIZE THIS INFORMATION TO:
PROVIDE YOU WITH THE INFORMATION, PRODUCTS, OR SERVICES YOU REQUEST FROM US.
FULFILL THE PURPOSE FOR WHICH YOU PROVIDED THE INFORMATION.
ESTABLISH, MAINTAIN, PERSONALIZE, AND SECURE YOUR ACCOUNT WITH US.
CUSTOMIZE YOUR WEBSITE EXPERIENCE AND DELIVER CONTENT AND OFFERINGS RELEVANT TO YOUR INTERESTS, INCLUDING TARGETED ADVERTISEMENTS AND OFFERS THROUGH OUR WEBSITE, THIRD-PARTY PLATFORMS, AND VIA EMAIL OR TEXT MESSAGE (WITH YOUR CONSENT WHERE REQUIRED BY LAW).
PROMOTE AND MARKET PRODUCTS AND SERVICES TO YOU FROM BOTH AFFILIATED AND NON-AFFILIATED ENTITIES, INCLUDING SENDING PROMOTIONAL COMMUNICATIONS, TARGETED ADVERTISING, AND PRESENTING YOU WITH RELEVANT OFFERS (WITH YOUR CONSENT WHERE REQUIRED BY LAW).
ENSURE THE SAFETY, SECURITY, AND INTEGRITY OF OUR WEBSITE, PRODUCTS AND SERVICES, DATABASES, AND OTHER TECHNOLOGY ASSETS, AS WELL AS OUR BUSINESS OPERATIONS.
PROCESS YOUR REQUESTS, PURCHASES, TRANSACTIONS, AND PAYMENTS.
OFFER YOU SUPPORT AND ADDRESS YOUR INQUIRIES, INCLUDING INVESTIGATING AND RESOLVING YOUR CONCERNS AND ENHANCING OUR RESPONSES.
CONDUCT TESTING, RESEARCH, ANALYSIS, AND PRODUCT DEVELOPMENT, INCLUDING IMPROVING OUR WEBSITE, PRODUCTS, AND SERVICES.
RECEIVE INFORMATION FROM THIRD-PARTY BUSINESS PARTNERS, INCLUDING SOCIAL MEDIA PLATFORMS, ADVERTISING NETWORKS, AND ANALYTICS SERVICE PROVIDERS.
RESPOND TO LAW ENFORCEMENT REQUESTS AND COMPLY WITH APPLICABLE LAWS, COURT ORDERS, OR GOVERNMENTAL REGULATIONS.
DISCLOSE INFORMATION TO YOU AT THE POINT OF COLLECTION OR AS OTHERWISE STATED IN THE CCPA.
DISCLOSURE OF PERSONAL INFORMATION FOR BUSINESS PURPOSES
SMART PATH ASSIST may share your personal information with third-party service providers for business purposes. We disclose your personal data to the following categories of third parties for business objectives:
PARTNER ENTITIES
VENDORS - WHEN SMART PATH ASSIST ENGAGES A VENDOR, IT ESTABLISHES A CONTRACTUAL AGREEMENT THAT OUTLINES THE BUSINESS OBJECTIVE AND MANDATES THE VENDOR TO: (A) MAINTAIN THE CONFIDENTIALITY OF THE PERSONAL INFORMATION; AND (B) UTILIZE IT EXCLUSIVELY TO FULFILL THE CONTRACTUAL OBLIGATIONS.
BANKING ENTITIES - OUR DISCLOSURE OF YOUR PERSONAL DATA TO THESE ORGANIZATIONS IS RESTRICTED TO INSTANCES WHERE YOU SPECIFICALLY AUTHORIZE US TO SHARE YOUR PERSONAL DETAILS WITH THEM.
IN THE PRECEDING TWELVE (12) MONTHS, SMART PATH ASSIST HAS SHARED THE FOLLOWING TYPES OF PERSONAL DATA FOR BUSINESS OBJECTIVES:
CATEGORY A: IDENTIFYING DETAILS.
CATEGORY B: CALIFORNIA CUSTOMER RECORDS PERSONAL DATA CATEGORIES.
CATEGORY C: PROTECTED CLASS CHARACTERISTICS UNDER CALIFORNIA OR FEDERAL LEGISLATION.
CATEGORY D: BUSINESS-RELATED DATA.
CATEGORY K: CONCLUSIONS DERIVED FROM ADDITIONAL PERSONAL INFORMATION.
TRANSFER OF PERSONAL INFORMATION
SIMILARLY, UNDER THE CCPA, SMART PATH ASSIST IS REQUIRED TO FURNISH YOU WITH INFORMATION REGARDING ITS PERSONAL INFORMATION TRANSFERS. THE DEFINITION OF “TRANSFER” UNDER THE CCPA IS QUITE BROAD. TO ENSURE COMPLIANCE, WE ARE ISSUING THE FOLLOWING NOTICE. WITHIN THE PRECEDING 12 MONTHS, WE MAY HAVE SHARED THE FOLLOWING CATEGORIES OF INFORMATION:
CATEGORY A: IDENTIFYING MARKS.
CATEGORY B: CALIFORNIA CUSTOMER RECORDS PERSONAL DATA CATEGORIES.
CATEGORY C: SAFEGUARDED CLASS CHARACTERISTICS UNDER CALIFORNIA OR FEDERAL LEGISLATION.
CATEGORY D: BUSINESS-RELATED DATA.
CATEGORY K: CONCLUSIONS DERIVED FROM ADDITIONAL PERSONAL DETAILS.
WE TRANSFER THESE PERSONAL DATA CATEGORIES FOR BUSINESS OBJECTIVES TO THE FOLLOWING TYPES OF THIRD PARTIES:BANKING INSTITUTIONS - THIS MAY INCLUDE ENTITIES SUCH AS DEBT SETTLEMENT SERVICE PROVIDERS AND LENDERS.
BUSINESS ASSOCIATES AND EXTERNAL PARTIES - WE MIGHT ALSO SHARE DETAILS WITH BUSINESS COLLABORATORS AND EXTERNAL PARTIES (SUCH AS OTHER CORPORATIONS, RETAILERS, RESEARCH INSTITUTES, ADVERTISERS, AD AGENCIES, ADVERTISING NETWORKS AND PLATFORMS, SOCIAL MEDIA NETWORKS, PARTICIPATORY DATABASES, PUBLISHERS, AND NON-PROFIT ORGANIZATIONS) THAT MAY WISH TO PROMOTE GOODS OR SERVICES TO YOU.
PLEASE BE AWARE THAT ONCE WE TRANSFER YOUR PERSONAL DATA TO ANOTHER COMPANY, THE INFORMATION RECEIVED BY THAT COMPANY IS UNDER THE CONTROL OF THAT COMPANY AND BECOMES SUBJECT TO THE PRIVACY PRACTICES OF THAT COMPANY.
YOUR RIGHTS REGARDING
ACCESS AND DATA PORTABILITY
YOU HAVE THE RIGHT TO REQUEST THAT SMART PATH ASSIST DISCLOSE THE PERSONAL INFORMATION WE COLLECT, USE, AND DISCLOSE. IF WE RECEIVE AND VERIFY YOUR CONSUMER REQUEST AND NO EXCEPTION APPLIES, WE WILL PROVIDE YOU WITH:
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 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 SOLD OR DISCLOSED YOUR PERSONAL INFORMATION FOR A BUSINESS PURPOSE, TWO LISTS DISCLOSING:
SALES, IDENTIFYING THE PERSONAL INFORMATION CATEGORIES THAT EACH CATEGORY OF RECIPIENT PURCHASED; AND
DISCLOSURES FOR A BUSINESS PURPOSE, IDENTIFYING THE PERSONAL INFORMATION CATEGORIES THAT EACH CATEGORY OF RECIPIENT OBTAINED.
Requesting Deletion of Personal Information
WITH CERTAIN STIPULATIONS, YOU RETAIN THE AUTHORITY TO PETITION FOR THE ERASURE OF ANY PERSONAL DATA WE GATHERED AND KEPT FROM YOU. UPON RECEIPT AND VALIDATION OF YOUR CONSUMER INQUIRY, ABSENT ANY APPLICABLE EXEMPTIONS, WE SHALL PURGE (AND INSTRUCT OUR SERVICE PROVIDERS TO PURGE) SAID PERSONAL DATA FROM OUR DATABASES.
"The CCPA outlines various grounds upon which a deletion request may be declined. We reserve the right to refuse your deletion request if retaining the information is deemed necessary for either us or our service provider(s) to fulfill essential functions or obligations.
We may decline your deletion request if retaining the information is necessary to finalize the transaction for which we gathered your personal information, furnish a requested good or service, undertake actions reasonably expected within the framework of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall in accordance with federal law, or otherwise fulfill our contractual obligations to you.
We might deny your deletion request if retaining the data is essential for identifying security breaches, guarding against malicious, deceptive, fraudulent, or unlawful behavior, or pursuing legal action against those accountable for such actions
Our rationale or commercial objective for gathering that personal data
Uphold the exercise of free expression, safeguard the rights of other consumers to express themselves freely, or uphold any other rights granted by law.
Ensure compliance with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).Conduct public or peer-reviewed scientific, historical, or statistical research in the public interest, adhering to all relevant ethics and privacy laws.
Refusal of deletion may occur if data removal could hinder or significantly impede the research outcome, provided you have given informed consent previously. Facilitate internal utilization exclusively for purposes reasonably aligned with consumer expectations based on our relationship with you. Adhere to a legal mandate. Partake in scientific, historical, or statistical research of public interest, subject to peer review and ethical and privacy regulations. Refusal to delete data may occur if its removal could hinder or significantly impede the research outcome, provided prior informed consent was obtained. The entitlement to decline the sale of personal information You hold the privilege to request Smart Path Assist to cease selling your personal information.
To enact this right, kindly click on the following (link): "Do Not Sell My Personal Information" or contact us toll-free during business hours.Taking action on access, data portability, and deletion rightsTo enact the access, data portability, and deletion rights as detailed above, kindly submit a verifiable consumer request to Smart Path Assist
following process:
Filling out the California Consumer Request Form accessible by clicking the following (link). Only you or someone registered with the California Secretary of State and legally authorized to act on your behalf can make a verifiable consumer request concerning your personal information.You're permitted to make a verifiable consumer request for access or data portability twice within a 12-month timeframe.- Provide adequate information enabling Smart Path Assist to reasonably verify that you are the individual (or authorized representative) for whom personal information was collected. This may involve multi-factor authentication of the information provided by you.
Authentication may be conducted independently or in conjunction with a comparison of personal information already held by Smart Path Assist, if available. - Clearly describe your request with enough detail for Smart Path Assist to fully comprehend, evaluate, and address it.
We are unable to fulfill your request or disclose personal information unless we can authenticate your identity or confirm your authority to make the request, as well as establish that the personal information pertains to you. While creating an account is not necessary to make a verifiable consumer request, we must ensure the personal information is indeed yours.
Requests made through a password-protected account are deemed sufficiently verified if they pertain to personal information linked with that specific account.We will solely utilize personal information furnished in a verifiable consumer request to authenticate the requester's identity or validate their authority to make the request. RESPONSE TIME AND FORMAT. Smart Path Assist aims to address a verifiable consumer request within forty-five (45) days of its receipt.
Should additional time be necessary, up to a maximum total of ninety (90) days from the date of receipt, Smart Path Assist will notify you and provide the reason for the extension. If you have an online account with us, we will deliver our written response to your online account. If you do not possess an account with us, we will deliver our written response either by mail or electronically, based on your preference. Any disclosures provided will cover only the 12-month period preceding the receipt of the verifiable consumer request.
Additionally, our response will include explanations if we are unable to fulfill or have denied a request, where applicable.We do not impose a fee to process or respond to your verifiable consumer request unless it is deemed excessive, repetitive, or manifestly unfounded.
If we determine that the request warrants a fee, we will elucidate why we made that decision and furnish you with a cost estimate before proceeding with your request. Smart Path Assist is committed to not discriminating against you for exercising any of your CCPA rights as described above. Unless otherwise permitted by the CCPA, Guru Finance will not:
DENY YOU GOODS - Refuse to provide you with goods or services
Clearly articulate your request with adequate detail to ensure Smart Path Assist can comprehensively understand, assess, and respond to it.- Imply that you might be offered a disparate price, rate, level, or quality of goods or services based on your exercise of CCPA rights. How do we handle web browser "Do Not Track" signals or other mechanisms enabling consumers to exercise choice regarding the collection of personally identifiable information about an individual consumer's online activities over time and across third-party websites or online services?
Presently, we do not acknowledge DNT signals in browsers as we do not track individual users across the web.Could other parties collect personally identifiable information about an individual consumer's online activities over time and across different websites when they visit www.smartpathassist.com?
California's "Shine the Light" Law (Civil Code Section § 1798.83) allows specific individuals who are California residents to request information about our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please email us at or write to us at Smart Path Assist.
Updates to our Privacy Notice
We retain the right to modify this notice at our discretion and at any time. When alterations are made to this notice, we will publish the updated notice on our website and revise the notice's effective date. Your ongoing use of our website subsequent to the posting of modifications signifies your acceptance of such changes.
Smart Path Assist is dedicated to promptly addressing any inquiries or concerns you may have regarding this notice. If you have questions about how Smart Path Assist collects or utilizes your personal information as elucidated in this notice and our online privacy policy, the rights accorded to you under the CCPA, or how to exercise your rights, or if you are a consumer with a disability and wish to receive a copy of this notice, you can reach us
Smart Path Assist LLC
Phone: 844-476-0988
Please print and keep a copy of this California Privacy Notice for your records. For a PDF version of this privacy notice for California consumers suitable for printing as a separate document, please click below. You must have PDF software such as Adobe Acrobat Reader to view and print PDF documents. If you need Acrobat Reader, you can download it from Adobe for free by clicking here.Smart Path Assist LLC
