California Privacy Notice

This notice applies to California residents and supplements our Privacy Policy. It describes rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), to the extent that law applies to Borrova and the personal information and processing involved.

Where Borrova processes information on behalf of a lender, broker, or other business customer, that customer is responsible for its own privacy notices and responding to requests. We assist customers as applicable. Certain information governed by other laws may be exempt from some CCPA requirements; those exemptions do not necessarily apply to all information we process.

Depending on your use of the Services and the information you or our customers provide, we may collect the following categories:

• Identifiers and customer records. Names, contact details, account identifiers, mailing addresses, and identification information, including personal information described in California Civil Code Section 1798.80(e).
• Commercial and financial information. Application and property details, income, assets, liabilities, financial account information, tax records, and supporting documents.
• Professional or employment information. Employment history, employer details, and information submitted in connection with an application.
• Protected classifications. Demographic information where requested in an application and provided through the Services.
• Internet or electronic network activity. IP addresses, browser and device information, access times, service interactions, and delivery and error logs.
• Sensitive personal information. Social Security numbers, government identification, account login credentials, and financial account access information where provided through the Services. Submitted records may also contain demographic information treated as sensitive under the CCPA.

We collect information directly from you, from our customers and their authorized users, automatically through use of the Services, and from connected-account providers with your authorization.

We use this information to provide and maintain the Services; manage accounts and access; process applications, documents, and related records; deliver communications and support; monitor performance and troubleshoot issues; prevent fraud and misuse; and meet legal obligations and enforce agreements. Our Privacy Policy describes these purposes and automated document-processing features in more detail.

We may disclose the categories above for business purposes to customers and their authorized users, designated recipients, and service providers, as applicable to their role. Service providers support hosting, storage, authentication, email delivery, and document processing. Our Privacy Policy identifies providers and describes disclosures for legal, security, and business-transaction purposes.

We do not sell personal information or share it for cross-context behavioral advertising, as those terms are defined under the CCPA. We do not disclose personal information to advertising companies for targeted advertising.

Subject to applicable requirements and exceptions, you may have the right to:

• Know and access. Request the categories and specific pieces of personal information collected about you, its sources, the purposes of collection, and the categories of recipients to whom it is disclosed.
• Correct. Request correction of inaccurate personal information.
• Delete. Request deletion of personal information, subject to exceptions.
• Opt out. Opt out of the sale of personal information or its sharing for cross-context behavioral advertising, where applicable. Borrova does not engage in these practices.
• Limit. Limit certain uses and disclosures of sensitive personal information where that right applies.
• Equal treatment. Exercise your rights without unlawful discrimination or retaliation.

Email support@borrova.app with the subject “California privacy request” and describe the right you wish to exercise. You do not need to create an account. Do not include passwords, full Social Security numbers, or financial documents in your initial email.

We may request information reasonably necessary to verify your identity for access, correction, or deletion requests. An authorized agent may submit a request on your behalf. We may require proof of the agent’s authority and, where permitted, confirmation of your identity and authorization. Applicable sale or sharing opt-out requests are not subject to identity verification, although we may request information needed to apply a request.

If your information was submitted to or provided by a lender or another business customer, please direct your request to that organization. We may refer your request to the customer or assist it in responding.

For requests to know, correct, or delete that we are responsible for responding to under the CCPA, we will acknowledge receipt within 10 business days and respond within 45 calendar days. If a permitted extension is needed, we will explain the reason and notify you within the initial response period. An extension may be up to an additional 45 calendar days.

Applicable opt-out and limitation requests will be processed as soon as feasible and within 15 business days. Requests are subject to applicable legal requirements and exceptions, including verification and record-retention obligations.

We retain personal information for as long as reasonably necessary for the purposes described in our Privacy Policy. Retention depends on the nature of the information, our relationship with the customer, and applicable legal, recordkeeping, security, and dispute-resolution requirements. Information processed on behalf of a customer is also subject to that customer’s retention requirements.

Archiving does not delete a record. Residual copies may remain in backups for a limited period or be retained where required by law.

We will not unlawfully discriminate or retaliate against you for exercising your applicable CCPA rights, including by denying services, charging different prices, or providing a different level of service because you exercised those rights.

We may update this notice as our practices or applicable requirements change. We will post the revised notice here and update the date above, with additional notice of material changes where required by law.

For questions about this notice, contact Borrova at support@borrova.app.