California Privacy Notice

Effective Date: August 1, 2022

This California Privacy Notice (“CA Notice”) applies solely to individual residents of California (“consumers” or “you”) and supplements the information contained in our Privacy Policy.  All terms in this CA Notice have the same meaning as defined in our Privacy Policy or, if not defined in our Privacy Policy, as otherwise defined by the California Consumer Privacy Act (“CCPA”). For the purpose of this CA Notice, references to personal information mean “personal information” as defined by the CCPA (also referred to herein as “PI”).

Carve-outs to this CA Notice

There are certain sets of information that the CCPA does not apply to.  By way of some relevant examples, please note that this CA Notice does not apply to:

  • Information excluded from the CCPA’s scope, such as information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), and the California Financial Information Privacy Act (FIPA).
  • Publicly available information from government records.
  • Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
  • Information relating to job applicants or our employees, contractors, and other personnel.

Collection and Use of Personal Information

We collect personal information from and about you for a variety of purposes as set out in the “How We Use Personal Information We Collect Through the Qapital Service” section of our Privacy Policy. To learn more about the types of PI we collect and the purposes for which we use this information, please refer to our Privacy Policy.

In the last 12 months, we may have collected the following categories of PI:

  • Identifiers, such as your name, email address, or other similar identifiers.
  • California Customer Records (Cal. Civ. Code § 1798.80(e)), such as birth date, contact information, and payment information.
  • Commercial Information, such as payment and purchase history.
  • Internet/Network Information, such as device information, logs, and analytics data.
  • Geolocation Data, such as precise location information from your device or generated based on IP address or Wi-Fi.
  • Other Personal Information, such as information you share when you submit an inquiry or otherwise provide to us.
  • Inferences, such as predictions about your interests and preferences.

Disclosure of Personal Information

We take a position that we do not “sell” personal information (as such term “sold” is defined under the CCPA) about you but we have disclosed personal information with third parties for “business purposes” (see below).

For the categories of entities to whom we may disclose personal information for business purposes, please see “How We Share Information Collected” in the body of the Privacy Policy above.

In the previous 12 months, we may have disclosed all of the categories of PI we collect (explained above) to those entities for a business purpose.

California Consumer Rights

If you are a California consumer, as defined by the CCPA, you may be afforded additional rights with respect to your personal information. You may be able to exercise each of your rights as identified below, subject to certain limitations under the CCPA, such as the exceptions therein, and our verification of your identity.

  1. Access.  You have the right to request that we disclose certain information to you about our collection, use and disclosure of your personal information over the past twelve (12) months. Note that your right to receive personal information is limited to twice in a 12-month period.
  2. Deletion.  You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.
  3. Right to Opt Out of Sales.  We take the position that we do not “sell” personal information and that we do not have actual knowledge of “selling” personal information of consumers under sixteen (16) years of age.
  4. Non-Discrimination.  If a California data subject exercises his or her rights under the CCPA, we shall not discriminate against that California resident by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action.

Exercising Your Rights

To Exercise Your Right to Access or Right to Deletion

If you are a California resident who chooses to exercise your right to access or deletion, you can send us an email at Please see Account Deletion under Your Choices in the main Privacy Policy for more options and information with respect to your right to deletion.

Before processing your request, we may need to verify (a) that this request falls within the scope of the CCPA, given the carve-outs in the law (such as those set forth above) and (b) your identity and confirm you are a resident of the State of California (and, relatedly, if you submit a request via an authorized agent, we must verify that that such authorized agent is duly authorized).  In order to verify your identity, we will generally require the matching of certain information you provide us with the information we already maintain about you in our systems.  This process may require us to request additional personal information from you (e.g., email address).

California’s “Shine the Light Law”

California Civil Code Section § 1798.83 (“Shine the Light”) permits users of the Qapital Service that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.  This right granted to California residents applies only to their activities within the State of California.  To make such a request, please send an email to

Notice of Financial Incentives

In addition, we may offer you financial incentives for the collection, sale, retention, and use of your personal information as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms.  Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms.  We may add or change incentive programs, or their terms by posting notice on the program descriptions and terms linked to above, so check them regularly.

Each financial incentive or price or service difference related to the collection and use of personal information is based upon our reasonable, good-faith determination of the estimated value of such information to our business, taking into consideration the value of the offer itself and the anticipated revenue generation that may be realized by rewarding brand loyalty. We calculate the value of the offer and financial incentive by using the expense related to the offer.