This California privacy statement (“Statement”) is posted on the website located at https://ffequipmentleasing.com/ (“Website”) operated by First Financial Holdings, LLC dba First Financial Equipment Leasing (“First Financial,” “we,” “us,” or “our”) and describes our information privacy practices across our business, including our collection, use, and disclosure of personal information about California consumers as required by the California Consumer Privacy Act (“CCPA”). All defined terms within the CCPA, including those defined in Cal. Civ. Code § 1798.140, apply for the purposes of interpreting this Statement. This Statement is effective as of the date last updated, located at the bottom of this document.

While this Statement describes the practices we have adopted in California, privacy laws vary and some jurisdictions may place other restrictions on our collection, use, or disclosure of personal information. Our practices in such jurisdictions or for resident of other jurisdictions may be different or more limited than those described herein to comply with local requirements.

By accessing or using our Website or submitting information to us, you understand and consent to our collection and use of your personal information as described herein.

1. Information We Collect

Generally, we collect personal information as necessary to conduct our business and provide business services. This information may include correspondence and conversations you may have with us, including records or copies of your correspondence with us or customer service calls, and other communications, as well as personal and company name, email address, postal address, phone number, fax number, title; credit card; billing address; county; and signature. Personal information which can be used to directly identify an individual is “personally identifiable information” which is a subset of “personal information” for the purposes of this Statement.

We collect personal information in certain common cases, such as:

Website Form Information.

We collect any information you affirmatively provide us through forms or otherwise on the Website. This “Web Form Info” may include name, email address, phone number, survey responses, and any other information you choose to communicate to us.

Website Technical Information.

We collect certain information to help us operate and provide the Website to you. We collect this “Technical Info” when you use the Website, including:

• Information about the device you use to access the Website, such as IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device type, and device identifiers;
• Information about your visits to the Website we provide, including the full URL clickstream to, through and from the Website (including date and time);
• Information we need and use to facilitate your use of the Website (including to provide access to third party websites and services), such as URL requests, destination IP address, or device configuration details;
• Pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page.

Social Media.

If you choose to participate in First Financial-sponsored social media activities or offerings, we may collect certain information from your social media account consistent with your settings within the social media service, such as location, check-ins, activities, interests, photos, status updates and connections list. The personal information described in this paragraph is the “Social Data.”

We receive personal information from the following categories of sources:

• You, the consumer.
• First Financial Companies.
• Data analytics providers.
• Service providers.
• Social networks.

2. Cookies

Our Website uses cookies and similar technologies to support the functionality of the Website. Cookies are small files stored by your internet browser on your computer or mobile device, which allow our Website to store information such as user preferences. This provides a better experience when you visit the Website and allows us to improve the Website. The Website uses cookies for the following purposes: to track how many pages a user visits on the Website, to improve site performance and the convenience of the browser display functions. You can disable cookies by adjusting your browser settings. When you use our Website, cookies may collect information about your online activities over time and across other websites. We do not respond to “do not track” signals or other similar mechanisms at this time.

3. Purposes for Which We Collect Personal Information

We will use and share information you provide to us only as described in this Statement.

If you send us an email, fill out a contact form, call us, answer a survey, or choose to communicate with us in another way, we will collect that information in order to respond to your request, feedback, or question.  

We may use the information we collect to:

• Allow us to operate our Website, including administration, internal operations, troubleshooting, data analysis, testing, research, statistical and survey purposes;
• Manage your access to the Website;
• Send you the information that allows you to use the Website;
• Comply with laws and regulations;
• Maintain the security of the Website.
• Provide you with information about goods or services that may interest you;
• Send you emails, text messages, or other communications about updates, information, or alerts regarding the Website.

You can request more information regarding how we use your information for marketing purposes by sending an email to Info@FFEquipmentLeasing.com.

4. How We Share Personal Information

We will not sell, trade, or otherwise transfer your personally information without advance notice, except as described in this Statement.

We may provide your personally information to third party vendors, including Website hosting partners, and other parties who assist us in operating our Website, conducting our business, or servicing you. We will not provide your personally identifiable information to these types of vendors unless those parties agree to keep such information confidential, or you instruct us to share such information.

We may also release your information to our parent or subsidiary companies and their affiliated entities (“First Financial Companies”) or as we believe it is appropriate to comply with the law, enforce our Website policies, or protect ours or others’ rights, property, or safety.

We share personal information with the following categories of third parties:

• First Financial Companies.
• Contact management platforms.
• Data analytics providers.
• Service providers.
• Social Networks.

Categories of Personal Information Collected, Disclosed, and Sold.

*We do not currently sell personal information, however our prior use of common web analytics tools may be considered a sale under the California Consumer Privacy Act. To comply with the law and respect the privacy of our users, we have altered our implementation of these tools to not sell personal information.

Our Website utilizes Google Analytics. For more information about the specific information shared with this service, please visit https://www.google.com/policies/privacy/partners.

5. Your Choices

When exercising the rights or options described in this Statement, you will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.

When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Updating Your Info.

You can update information we hold about you by contacting us through our Contact form.

Opting Out.

Promotional and Other Emails. To stop receiving newsletters, surveys, offers, or other materials from us, you may send a request via the Contact form, or clicking the unsubscribe link contained in the communication, if applicable. If you decide not to receive such promotional emails, we may still send you communications related to your current or former relationship with us.

Behavioral Advertising. Our Website may use tools that integrate behavioral advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our websites so that they can provide advertising about products and services tailored to your interests. That advertising may appear either on our Website, or on other websites not operated by us. If you do not want third parties who collect information about your use of our services, you can opt-out of such at the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe.

PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING SERVICES. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.

Analytics. Many analytics providers allow end-users to opt out of the retention of their information, including our third-party analytics providers. Please note that typically, unless you create an account with the analytics provider, your choice to opt out applies only to the device from which you make the request, because the providers use cookies on that device to recognize your choice. If you get a new device, install a new web browser, update your browser, or otherwise erase/alter your browser cookie files you may clear the opt-out cookie.

You may learn more about opting-out of analytics from our third-party provider by visiting its opt-out page at the following links:

https://tools.google.com/dlpage/gaoptout

6. Your California Privacy Rights

As a California consumer, you have the right to request that we disclose what personal information about you we collect, use, disclose, and sell. More specifically, you have rights to the following without charge:

Disclosure of Personal Information We Collect About You

You have the right to know, upon submission of a verifiable request, the categories of personal information we have collected about you, the categories of sources from which we collect personal information, our business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share personal information, if any, and the specific pieces of personal information we have collected about you.

We will not retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; not reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; and reserve our right not to provide personal information to you more than twice in a 12-month period.

Disclosure of Personal Information Sold or Disclosed for a Business Purpose

In connection with personal information we may sell or disclose for a business purpose, if any, you have the right to know the categories of personal information about you that are sold and the categories of third parties to whom the personal information is sold, and the categories of personal information that are disclosed about you for a business purpose, and the categories of third parties to whom personal information is disclosed for a business purpose.

Your Right to Opt-Out of the Sale of Personal Information

A “sale” under California law is defined as any transfer of personal information for value. Because personal information is valuable to many businesses, many commonplace transfers are considered to be sales under the law. We do not sell personal information. If in the future we do sell personal information, you will be given notice and an opportunity to opt-out of sales.

Deletion of Personal Information

Subject to the exceptions set out below, and upon your submission of a verifiable request, you have the right to deletion of your personal information from our records, and to have us direct our service providers delete your personal information from their records.

We are not required to, and reserve our right not to, delete your personal information it if is necessary to complete the transaction for which the personal information was collected or reasonably anticipated within the context of our ongoing business relationship with you, provide a good or service requested by you, or otherwise perform a contract between you and us; detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity; debug, identify, or repair errors that impair existing intended functionality; exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; comply with the California Electronic Communications Privacy Act; enable solely internal uses that are reasonably aligned with your expectations based on the your relationship with us; comply with an existing legal obligation; and otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information. The foregoing list of exceptions to the deletion right is provided for informational purposes only, and in no way limits the circumstances in which such requests for deletion may be denied beyond the limitations imposed by applicable law.

Children’s Personal Information

We do not knowingly collect personal information and do not sell the personal information of individuals under 16 years of age. Our Website is available only to individuals and entities that can form legally binding contracts under applicable law. You warrant that you are eighteen (18) years of age or older to use our Website. If you do not qualify, you may not use our Website. If you are a parent or legal guardian, please do not to allow your children to submit personal information to us.

Freedom from Discrimination

You have the right to not be discriminated against by us if you exercise any of your rights under the California Consumer Privacy Act. This means we cannot do any of the following on the basis of your exercise of these rights: deny goods or services to you; charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to you; or suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Shine The Light Requests

Individual customers who reside in California and have provided us certain personal information may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must include your name, street address, city, state, and zip code, and be submitted to us at one of the following addresses: Info@FFEquipmentLeasing.com with the subject “California Shine The Light Request.” Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

7. How to Exercise Your Rights

Residents of California may, unless otherwise specified, exercise any of your rights described in this Statement, by completing a consumer request form available here, calling us toll-free at 1-（877）411-3335 or submitting a request to us in writing at the following address: First Financial Corporate Services, Inc., ATTN: California Privacy Request – CCPA, 750 The City Drive South Ste. 300, Orange, CA  92868

In order to verify your request, you will need to provide us with enough information to identify you (e.g., your full name, address,), 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.

You may also designate an authorized agent to make a request under the California Consumer Privacy Act 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 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 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.

8. Employment and Business-to-Business Information

The foregoing sections of this Statement do not include information collected for employment related purposes (“Employment Information”) or where your communications or transactions with us occur solely in the context of due diligence regarding, or providing or receiving a product or service to or from a company, partnership, sole proprietorship, nonprofit, or government agency on whose behalf you are acting (“B2B Information”).

From time to time, we have and we may in the future collect Employment Information.  The categories of personal information we may collect include information that identifies, relates to, describes, or is capable of being associated with, a particular individual; characteristics of protected classifications under California or federal law; internet or other electronic network activity; geolocation data; sensory data; professional or employment-related information; and education information.

We use Employment Information for the purposes of evaluating qualifications related to your job, providing employee compensation, benefits, and services in the context of the employment relationship, auditing, or detecting security incidents.

9. Changes To This California Privacy Statement.

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.

10. Date Last Updated

This Statement was last updated and is effective Aug 20^th , 2020. 

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