PRIVACY POLICY
Effective Date: January 1, 2023
1. OVERVIEW
This privacy policy (this “Policy”) applies to First Financial Holdings, LLC (“we,” “us,” or “our”). We strive to deliver outstanding products and services and value our customers’ business and loyalty. We recognize that privacy is an important issue. We have developed this Policy to explain our practices regarding the personal information we collect from you or about you when you use this website, communicate with us verbally or in writing, or otherwise in connection with our products and services. While this Policy broadly describes the practices we have adopted within North America, local laws vary, and some jurisdictions may place restrictions on our collection, use, or disclosure of personal information. Our actual practices in such jurisdictions may be more limited than those described in this Policy to comply with local requirements. If you are a resident of California, please see Appendix A for information regarding your rights under California law. By accessing or using our website or submitting information to us, or otherwise agreeing to this Policy, e.g., in the context of registering for any of our products or services, you understand and consent to our collection and use of your personal information as described herein.2. PERSONAL INFORMATION WE COLLECT AND USE
Personal information is information that identifies, relates to or describes you or can reasonably be associated with or linked to you. We collect and use personal information in certain common cases, including the following:Website Form Information
Automatically Collected Website Use Information
Social Media.
Security
Employees
Individuals Representing Businesses
3. SOURCES FROM WHICH WE COLLECT PERSONAL INFORMATION
We may collect personal information about you from a number of sources in addition to those means of collection indicated above, including offline or through sources unrelated to your use of our website. For example, we may collect personal information from publicly accessible sources (e.g., property records); directly from a third party, (e.g., credit reporting agencies or customer due diligence providers); or from a third party with your consent (e.g., your bank). We may merge or co-mingle that personal information with the personal information we maintain about you and other data collected on or through our website. Categories of sources from which we may collect personal information include: affiliated companies; service providers (including data analytics providers); contractors; social networks and government entities.4. PURPOSES FOR WHICH WE COLLECT PERSONAL INFORMATION
In addition to the purposes set forth in Section 2 above, we may collect your personal information for the following purposes:Auditing
Security
Debugging
Transient Use
Services
Advertising
Research
Quality and Safety
Commercial Interests
5. LIMITED USE OF PERSONAL INFORMATION
We will only use your personal information for the purposes for which we have collected it, unless we reasonably determine we need to use it for another reason and that reason is compatible with the original purpose. For example, we consider de-identification, aggregation, and other forms of anonymization of personal information to be compatible with the purposes listed above and in your interest, because the anonymization of such information reduces the likelihood of improper disclosure of that information. If you wish to receive an explanation as to how the processing for a particular purpose is compatible with the original purpose, please contact us via the information specified in the Contact section below.6. OUR DISCLOSURE OF PERSONAL INFORMATION
In order to provide you with the best products and services, we may disclose your personal information to our affiliates, service providers, contractors and other third parties as described below.Affiliates
Commercial Customers
Contractors
Service Providers
Third Parties
Compliance with Laws
Sale or Transfer of Business or Assets
7. COOKIES AND OTHER TRACKING TECHNOLOGIES
Third parties, including Google and Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our website and elsewhere on the internet and use that information to provide measurement services and target ads. You can opt-out of the collection and use of information for ad targeting using the options described in the Opting Out section below. The tracking technologies we utilize include the following:Cookies
Analytics
7.3 BY USING OUR WEBSITE, YOU GIVE CONSENT FOR US TO SHARE YOUR DATA WITH THESE PROCESSORS, AND FOR THEM TO TRANSFER THIS INFORMATION ONWARD TO THEIR PARTNERS IN CONNECTION WITH PROVIDING YOU SERVICES.
8. Opting Out
You can make the following choices regarding your personal information:Promotional and Other Emails
Behavioral Advertising
Analytics
Cookies
Do Not Track
9. INTERNATIONAL TRANSFERS OF INFORMATION
Your personal information may be processed in the country in which it was collected and in other countries, where laws regarding personal information may be less stringent than the laws in your country. Therefore, in some circumstances, you might be left without a legal remedy in the event of a privacy breach or other use that is prohibited in your country. By submitting your personal information, you agree to this transfer, storage and/or processing, including all associated risks.10. INFORMATION SECURITY
No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. We make efforts to protect your personal information from improper or unauthorized loss, misuse, access, disclosure, alteration, or destruction. If you have questions about the security of your personal information, contact us at the email or regular mail address specified in the Contact section below.11. DATA RETENTION
First Financial reserves the right to revise this Statement at any time. Such revision may arise in response to changes in the law, policy, or other factors. Any amendment will be effective immediately upon posting the amended Statement on the Website. We encourage you to visit this page periodically to review our most current policy. By continuing to access and use the Website, you agree to be bound by the amended Statement.12. THIRD-PARTY LINKS
Our website may contain links to other websites or apps. We are not responsible for the privacy practices or the content of these other websites or apps. You should read the policy statement of these other websites or apps to understand their policies. When you access linked websites or apps, you may be disclosing private information. It is your responsibility to keep such information private and confidential.13. CHANGES TO THIS PRIVACY POLICY
We may update this Policy from time to time, in our sole discretion. When we do so, we will post the new Policy on our website. You should consult this Policy regularly for any changes. Continued use of services following posting of such changes constitutes your acknowledgement of such changes and agreement to be bound by the changes. If you do not agree, you should immediately discontinue your use of our website and services.14. CONTACT US
If you have questions regarding this Policy, its appendices, or our treatment of your personal information, you may contact us at: First Financial Holdings, LLC. 750 The City Drive South, Suite 300 Orange CA 92858 Attention: Privacy or Info@FFEquipmentLeasing.com with the subject “Privacy”APPENDIX A
CALIFORNIA PRIVACY RIGHTS NOTICE
Effective Date: January 1, 2023
1. YOUR CALIFORNIA PRIVACY RIGHTS UNDER THE CCPA
Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), if you are a resident of California you have the following rights with respect to your personal information.14.1 Right to Know About Our Collection, Disclosure, Sharing and Sale of Personal Information about You.
14.2 Right to Know About Our Collection, Disclosure, Sharing and Sale of “Sensitive” Personal Information about You.
14.3 Right to Delete Your Personal Information.
14.4 Right to Correct Inaccurate Personal Information.
14.5 Right to Be Free from Discrimination.
14.6 Right to Opt-Out of the Sharing of Personal Information.
14.7 Right to Opt-Out of the Sale of Personal Information.
14.8 Right to Opt-Out by Using Opt-Out Preference Signals.
14.9 Right to Limit the Use of “Sensitive” Personal Information.
14.10 Children’s Personal Information.
15. HOW TO EXERCISE YOUR CCPA RIGHTS
Unless otherwise specified, to exercise any of your rights described in this Appendix A, please complete a consumer request available at CCPA REQUEST FORM or call us at 1-877-411-3335. In order to verify your request, we will need you to provide us with enough information to identify you (e.g., your full name, address, and customer or matter reference number), proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill), and a description of what right you wish to exercise along with any information to which your requests relates. If feasible, we will match the identifying information provided by you with the personal information that we already maintain about you. You may designate an authorized agent to make a request under the CCPA on your behalf. In order to fulfill your request to know or delete submitted by an authorized agent, you must provide the authorized agent written permission to do so, and we may require that you verify your own identity with us directly. We reserve our right not to grant a consumer request if we cannot verify that the person making the request is the person about whom we have collected information, or someone authorized to act on such person’s behalf. You may only make a request to access or receive copies of personal information twice within a 12-month period. Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.16. OUR PERSONAL INFORMATION COLLECTION, USE AND DISCLOSURE PRACTICES
A description of the personal information that we collect online and off-line is provided in Section 2 of the main Policy. The purposes for which we collect and use personal information are described in Sections 2 and 4 of the main Policy. Sources from which we receive personal information are described in Section 3 of the main Policy. Our personal information disclosure practices are described in Sections 6 and 7 of the main Policy. Our personal information retention practices are described in Section 11 of the main Policy.16.1 Categories of Personal Information Collected; Sold or Shared for Cross-Context Behavioral Advertising; and Disclosed for a Business Purpose within the past 12 months.
Category of Personal Information | Information Collected | Sold or Shared in the Past 12 Months? | Categories of Third Parties to Whom Sold or Shared | Disclosed for a Business Purpose in Past 12 Months? | Categories of Third Parties to Whom Disclosed |
|---|---|---|---|---|---|
Individual
Identifiers | Inquiry Data;
Use Data;
Social Data;
Security Data;
Employee Data;
Biz Rep Data | No | None | Yes | Contractors;
Service
Providers;
Government
Entities;
Affiliates |
Categories
Described in
California
Consumer
Records Act,
Civil Code
§1798.81.5 | Inquiry Data;
Use Data;
Social Data;
Security Data;
Employee Data;
Biz Rep Data | No | None | Yes | Contractors;
Service
Providers;
Government
Entities;
Affiliates |
Characteristics of
protected
classifications
under California
or federal law. | Employee Data | No | None | Yes | Contractors;
Service
Providers;
Government
Entities;
Affiliates |
Commercial
information. | Employee Data;
Biz Rep Data | No | None | Yes | Contractors;
Service
Providers;
Government
Entities;
Affiliates |
Biometric
information. | Employee Data | No | None | Yes | Contractors |
Internet or other
electronic
network activity. | Use Data | No | None | Yes | Contractors;
Service
Providers |
Geolocation data. | Security Data
Employee Data | No | None | Yes | Contractors;
Service
Providers;
Governmental
Entities |
Audio, electronic,
visual, thermal,
olfactory, or
similar
information. | Security Data | No | None | Yes | Contractors;
Service
Providers’
Governmental
Entities; |
Professional or
employment-related
information. | Employee Data;
Biz Rep Data | No | None | Yes | Contractors;
Governmental Entities |
Education
information. | Employee Data;
Biz Rep Data | No | None | Yes | Contractors;
Service
Providers;
Affiliates |
Inferences drawn
from any of the
information
identified above. | None | No | None | No | None |
16.2 Categories of “Sensitive” Personal Information Collected; Sold or Shared for Cross-Context Behavioral Advertising; and Disclosed for a Business Purpose within the past 12 months.
Category of Sensitive Personal Information | Information Collected | Shared or Sold in the Past 12 Months? | Categories of Third Parties to Whom Shared or Sold | Disclosed for a Business Purpose in Past 12 Months? | Categories of Third Parties to Whom Disclosed |
|---|---|---|---|---|---|
Social Security,
Driver’s License,
State ID, Passport
Number | Employee Data;
Biz Rep Data | No | None | Yes | Service
Providers;
Contractors |
Account Log-in
and Password | Employee Data;
Biz Rep Data | No | None | Yes | Service
Providers;
Contractors |
Financial
Account, Debit
Card, Credit Card
Number and
account access
information. | Employee Data;
Biz Rep Data | No | None | Yes | Service
Providers;
Contractors |
Precise
Geolocation. | Security Data;
Employee Data | No | None | Yes | Service
Providers |
Racial or ethnic
origin, religious
or philosophical
beliefs or union
membership. | Employee Data | No | None | No | None |
Contents of e-
mail, text
messages unless
we are intended
recipient. | Employee Data | No | None | No | None |
Genetic Data | No | No | None | No | None |
Biometric
Information for
purpose of
identification. | No | No | None | No | None |
Health
information
collected and
analyzed. | Employee Data | No | None | No | None |
Sex life or sexual
orientation
collected and
analyzed. | No | No | None | No | None |
