Last Updated: 03/10/2022
APPLICABILITY OF CCPA PRIVACY NOTICE
This Privacy Notice (“Notice”) applies solely to California residents and supplements Anchorage’s Online Privacy Notice. We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”).
Under the CCPA, ‘Personal Information’ is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked directly or indirectly with a particular California resident or household.
The CCPA, however, does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act (“GLBA”), the Fair Credit Reporting Act, and certain other state or federal privacy laws. For example, this CCPA Notice does not apply to information that we collect about Individuals located in the U.S. who seek, apply for, or obtain our financial products and services for personal, family, or household purposes, which is subject to our U.S. Consumer Privacy Notice (available on our Anchorage Privacy Center page).CATEGORIES OF PERSONAL INFORMATION WE COLLECT AND DISCLOSE
Most of the information we collect is in the context of providing financial products or services and is therefore not subject to the CCPA. We do collect Personal Information relating to California residents in other contexts, including marketing activities and interaction with our website.
In the past 12 months, we may have collected and disclosed to third parties for our business purposes the following categories of Personal Information about you in several ways when you use our services, as described below:
Identifiers: name, email, and address (e.g., Social Security Number);
Personal Information, as defined in the California safeguards law: contact and financial information;
Characteristics of protected classifications under California or federal law: sex and marital status;
Commercial Information: products or services purchased and account information;
Internet or other similar network activity: browser type, pages viewed, and links clicked;
Biometric Information: video footage and voiceprints;
Geolocation Data: device location;
Professional or employment-related information: occupation or prior employer;
Sensory Data: audio recordings of customer care calls, electronic, visual or similar information; and
Inferences are drawn from any of the Personal Information listed above to create a profile about, for example, an Individual’s preference and characteristics.
SOURCES OF PERSONAL INFORMATION
The categories of sources from whom we collect Personal Information are:
Directly from a California Resident: We collect information when you register on our site or fill out a profile. We also collect information when you create an account with Anchorage (including the identity verification process), subscribe to our promotional campaigns, or respond to a survey.
From Third Parties: We may collect information through referrals from other Anchorage users, from an Individual’s employer, or from our service providers (e.g., those that validate identity).
From Individuals Passively: We use third party tools to collect information from Individuals from our website and mobile application.
Publicly Available Information: We collect information about you via publicly available resources listed in our Online Privacy Notice.
Combining Information: We combine information received from third parties with information already stored. Anchorage may also combine information from an Individual’s profile with information submitted from surveys.
HOW WE USE PERSONAL INFORMATION
Most of the information we use is for the provision of financial products or services and is therefore not subject to the CCPA. We may use Personal Information of California residents for one or more of the following business purposes as described below.
Auditing related to counting ad impressions;
Ensuring security and integrity of our use of your Personal Information;
Debugging to repair errors to ensure our products’ functionality;
Marketing, particularly short-term use of Personal Information for non-personalized advertising;
Business services, including servicing accounts, customer service, processing transactions, etc.;
Internal research for technological development;
Maintaining the quality and security of Anchorage services.
Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law
SALE OF PERSONAL INFORMATION
As a California resident, you have the right to direct a business that sells your Personal Information to third parties not to sell your Personal Information. This right is referred to as “the right to opt-out of sale of Personal Information.”
Because we do not sell your Personal Information, we do not provide any mechanism for you to exercise the right to opt out.
CATEGORIES OF THIRD PARTIES DISCLOSURE
We may disclose Personal Information to the following third parties for a business purpose.
Category Examples Affiliates Anchorage Digital Bank, N.A.; Anchorage Hold, LLC; Anchorage NY, LLC; Anchorage Lending CA, LLC; Anchorage Global, LLC; Anchorage Services, LLC; Digital Assets Anchorage, Unipessoal, Lda. Service Providers Ironclad, DocuSign, Salesforce, Google, Chainalysis, TRM, Jira, DocSend, Front, Telegram, Slack, Aircall, Thomson Reuters Clear, RDC, Kroll Joint Marketing Partners Hubspot Government Entities Office of the Comptroller of the Currency (“OCC”), California Department of Financial Protection and Innovation (“DFPI”) Third Party Responsibilities – Any third parties that we share your Personal Information with are limited by law and by contract in their ability to use your Personal Information. Anchorage requires third-party service providers acting on our behalf or with whom we share your information to provide appropriate security measures in accordance with industry standards and in compliance with this Policy, their privacy and security obligations, and any other appropriate confidentiality and security measures. However, we are not responsible for the privacy and data security practices of third parties outside of Personal Information we receive from or transfer to them.
PRIVACY CHOICES AND RIGHTS
The CCPA provides California residents with specific rights regarding their Personal Information. If you are a California resident, you may have the following rights.
Request we disclose to you free of charge the following information covering the 12 months preceding your request:
the categories of Personal Information about you that we collected;
the categories of sources from which the Personal Information was collected;
the business or commercial purpose for collecting Personal Information about you;
the categories of third parties with whom we share that Personal Information; and
the specific pieces of Personal Information we collected about you.
Request that we delete any of your Personal Information we collected from you, unless a CCPA exception is applicable
Be free from unlawful discrimination for exercising your rights under the CCPA
We will acknowledge receipt of your request and advise you how long we expect it will take to respond if we are able to verify your identity. Requests for specific pieces of Personal Information will require additional information to verify your identity.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. If you are an authorized agent, please send us proof that the consumer gave you written permission to submit the request and we will verify your identity as provided above. We may also require the consumer to verify their own identity with us and/or directly confirm with us that they have given you permission to submit the request.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
We will work to process all verified requests within 45 days pursuant to the CCPA. If we need an extension for up to an additional 45 days in order to process your request, we will provide you with an explanation for the delay.
If you are a California resident, you may submit a request by:
Emailing us at privacy@anchorage.com.
CHANGES TO THIS NOTICE
We may change or update this CCPA Notice in the future. When we do, we will post the revised CCPA Notice on our website. This CCPA Notice was last updated and became effective on the date posted at the top of this page.
CONTACT US
If you have questions about this Notice, or if you wish to exercise any of your rights in relation to your Personal Information, please contact us. You can call us at (415) 610-0179 or write to us at privacy@anchorage.com.