This Privacy Notice for California Consumers (“Notice”), provided by Brite Path (“Brite Path,” “Company,” “we,” or “our”), supplements, and is expressly made part of, the information contained in the Brite Path Online Privacy Policy and applies solely to those who are consumers (“you” or “your”) as defined in Section 1798.140(g) of the California Consumer Privacy Act of 2018 (“CCPA”). We adopt this Notice in compliance with the CCPA and any terms defined in the CCPA have the same meaning when used in this Notice. Brite Path collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). As a consumer, you have certain rights regarding your personal information as defined in the CCPA. This Notice provides you with information on how Brite Path collects, uses, and shares personal information. It also outlines the rights you have regarding personal information that we collect from you and describes how you can exercise those rights. Collection and Use of Personal Information Brite Path recognizes the eleven (11) broad categories of personal information referenced in the CCPA that a business may collect about a consumer. In particular, Brite Path has collected the following categories of personal information from consumers within the last twelve (12) months:
Category
Examples
Collected
A. Identifiers.
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. It's worth noting that some personal information within this category may also be included in other categories.
YES
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.
YES
D. Commercial information.
Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies may be collected.
YES
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to derive a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data, may be collected.
NO
F. Internet or other similar network activity.
Information regarding a consumer's browsing history, search history, and interactions with websites, applications, or advertisements may be collected.
YES
G. Geolocation Data
Data related to the physical location or movements of individuals may be recorded.
NO
H. Sensory Data
Information captured through audio, electronic, visual, thermal, olfactory, or similar means may be collected.
NO
I. Professional or employment-related information.
Current or past job history or performance evaluations.
NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Data concerning educational records linked directly to a student and maintained by an educational institution or its representatives may include grades, transcripts, class rosters, student timetables, student ID numbers, student financial details, or student disciplinary records.
NO
K. Inferences drawn from other personal information.
Information that portrays an individual's inclinations, traits, psychological patterns, propensities, conduct, attitudes, intellect, capacities, and skills.
YES
As a financial institution under the Gramm-Leach-Bliley Act (GLBA), Brite Path engages in financial activities. While the CCPA does not provide exemptions for financial institutions, Section 1798.145(e) of the CCPA exempts personal information collected by financial institutions in accordance with the GLBA. Notably, personal information excludes data available from government records, de-identified or aggregated consumer information, or information exempted from the CCPA's scope, including data collected pursuant to the GLBA. We have acquired the categories of personal information outlined above from the following sources:
We obtain personal information directly from you. This includes information provided through forms you fill out or products and services you purchase from us.
We also collect personal information indirectly from you. This may include information we gather while providing services to you or by observing your actions on our website.
Additionally, we obtain personal information from third-party business partners, which may include social media platforms, advertising networks, and analytics providers, among others.
Brite Path may use this information to:
Provide you with the information, products, or services you request from us.
Fulfill the reason you provided the information.
Create, maintain, customize, and secure your account with us.
Personalize your website experience and deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site, third-party sites, and via email or text message (with your consent where required by law).
Advertise and market products and services to you from both affiliated and non-affiliated entities, which includes sending promotional communications, target advertising, and presenting you relevant offers (with your consent where required by law).
Help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
Process your requests, purchases, transactions, and payments.
Provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
For testing, research, analysis, and product development purposes, which include enhancing and refining our website, products, and services.
From third-party business partners including, but not limited to, social media sites, ad networks, and analytics providers.
Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As previously described to you during the collection of your personal information or as otherwise outlined in the CCPA.
Brite Path may disclose your personal information to third-party service providers for business purposes. We share your personal information with the following categories of third parties for business purposes:
Affiliates.
When Brite Path shares personal information with a Service Provider, it engages in a contractual arrangement specifying the business purpose. This agreement mandates the provider to: (A) maintain confidentiality of the personal information, and (B) solely utilize it to fulfill obligations outlined in the contract.
Our sharing of your personal information with financial institutions only occurs when you explicitly instruct us to share your personal information with these entities.
In the preceding twelve (12) months, Brite Path has disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category K: Inferences drawn from other personal information
Sale of Personal Information
Under the CCPA, Brite Path must provide you with a statement regarding its sale of personal information. The definition of "Sale" under the CCPA is broad. Out of an abundance of caution, we are giving you the following notice. In the past 12 months, we may have disclosed the following categories of information for sale:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category K: Inferences drawn from other personal information
We sell these categories of personal information for commercial purposes to the following categories of third parties:
Financial Institutions –including, for example, Debt Settlement Service Providers and Lenders.
Business partners and third parties – We may also share Information with business partners and third parties (e.g., other companies, retailers, research organizations, advertisers, ad agencies, advertising networks and platforms, social networks, participatory databases, publishers, and non-profit organizations) that may want to market products or services to you.
Please note that once we sell your personal information with another company, the information received by the other company is controlled by that company and becomes subject to the other company’s privacy practices.
Notice Regarding Your Rights
Access & Data Portability Rights:
You have the right to request that Brite Path disclose what personal information we collect, use, and disclose. If we receive and confirm your consumer request as verifiable and no exception applies, we will provide you with:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you.
If we sold or disclosed your personal information for a business purpose, two lists disclosing:
Sales, identifying the personal information categories that each category of recipient purchased; and
Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
Subject to certain exceptions, you have the right to request that we delete any of your personal information that we collected from you and retained. If we receive and confirm your consumer request as verifiable, unless an exception applies we will delete (and direct our service providers to delete) your personal information from our records.
The CCPA provides a number a reasons why a deletion request may be denied. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Our business or commercial purpose for collecting that personal information.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
To exercise your access, data portability, and deletion rights as described above, please submit a verifiable consumer request to Brite Path by:
Filling out the California Consumer request form available at by clicking here.
only you or an individual registered with the California Secretary of State and legally authorized to act on your behalf may submit a verifiable consumer request regarding your personal information. You are limited to making a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Please provide enough information for Brite Path to verify, with reasonable certainty, that you are the individual about whom Brite Path has collected personal information, or that you are an authorized representative. This may involve multi-factor authentication using identifying information provided by you. Authentication may be conducted independently or by comparing the information provided with personal information already held by Brite Path, if available.
Please provide detailed information about your request so that Brite Path can adequately understand, evaluate, and respond to it. The more specific and clear you can be about your request, the better we can address your needs and concerns.
We cannot fulfill your request or provide personal information without verifying your identity or authority to make the request. While you don't need to create an account, we need to confirm that the information relates to you. Requests made through a password-protected account are considered verified. Personal information obtained through a verifiable request is solely used for verification purposes.
We aim to respond to verifiable requests within 45 days. If we need more time, up to 90 days in total, we'll notify you and explain why. Responses will be provided through your online account if available; otherwise, they'll be sent by mail or electronically. Disclosures will cover the preceding 12-month period, and we'll explain any denials or reasons for non-compliance.
There's no fee for processing requests unless they're excessive, repetitive, or unfounded. If a fee applies, we'll explain why and provide a cost estimate beforehand.
Non-Discrimination
Brite Path will not retaliate against you for exercising any of your CCPA rights outlined above. Guru Finance will refrain from:
Deny you goods or services.
Please provide detailed information about your request so that Brite Path can accurately understand, assess, and address it.
Please ensure that your request includes enough specific details for Brite Path to effectively comprehend, assess, and provide a suitable response.
Please note that you may receive different pricing, rates, or levels of goods or services based on your exercise of CCPA rights.
We currently do not respond to "do not track" signals in browsers since we do not track individual users across the web. As for the collection of personally identifiable information about an individual consumer’s online activities over time and across different websites when they visit www.BRITEPATH.com, no, other parties do not collect such information.
Under California’s “Shine the Light” law (Civil Code Section § 1798.83), California residents have the right to request information about our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please email us at support@britepathsolutions.com or write to us at:Brite Path LLC,
We reserve the right to amend this Notice at our discretion and at any time. Changes will be posted on our website along with the updated effective date. Your continued use of our website following the posting of changes constitutes acceptance of such changes.
Brite Path LLC
Phone: 833-846-7427
Please print and retain a copy of this California Privacy Notice for your records. For a PDF version of this Privacy Notice For California Consumers suitable for printing as a separate document, please click below. You must have PDF software such as Adobe Acrobat Reader in order to view and print PDF documents. If you need Acrobat Reader, you can download it from Adobe for free by clicking here.
