Important Privacy Notice for California Consumers

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This Privacy Notice for California Consumers (“Notice”), provided by Three Pillar Partners LLC (“Three Pillar Partners LLC” “Company,” “we,” or “our”), supplements, and is expressly made part of, the information contained in the Three Pillar Partners LLC 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.

Three Pillar Partners LLC 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 Three Pillar Partners LLC 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.

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‍Collection and Use of Personal Information

‍‍Three Pillar Partners LLC recognizes the eleven (11) broad categories of personal information referenced in the CCPA that a business may collect about a consumer. In particular, Three Pillar Partners LLC has collected the following categories of personal information from consumers within the last twelve (12) months:

As a company conducting financial activities, Three Pillar Partners LLC is classified as a "financial institution" under the Gramm-Leach-Bliley Act ("GLBA").

While the CCPA doesn't provide exemptions for financial institutions, Section 1798.145(e) of the CCPA exempts personal information collected by a financial institution pursuant to the GLBA.

Personal information excludes publicly available information from government records, de-identified or aggregated consumer information, or information excluded from the CCPA's scope, such as information collected under the GLBA. We have obtained the categories of personal information listed above from the following sources:

• We have obtained the categories of personal information listed above directly from you. For example, from forms you complete or products and services you purchase.
• We have obtained the categories of personal information listed above indirectly from you. For example, from information we obtain in the course of providing our services to you, or from observing your actions on our website.
• We have obtained the categories of personal information listed above from third-party business partners including, but not limited to, social media sites, ad networks, and analytics providers.

Three Pillar Partners LLC may use this information to:

• We collect personal information to provide you with the information, products, or services you request from us.
• We collect personal information to fulfill the reason you provided the information.
• We collect personal information to create, maintain, customize, and secure your account with us.
• We collect personal information to 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).
• We collect personal information to 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).
• We collect personal information to help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
• We collect personal information to process your requests, purchases, transactions, and payments.
• We collect personal information to provide you with support and respond to your inquiries, including investigating and addressing your concerns, as well as monitoring and improving our responses.
• We collect personal information for testing, research, analysis, and product development purposes, including the development and improvement of our website, products, and services.
• We obtain personal information from third-party business partners, such as social media sites, ad networks, and analytics providers.
• We obtain personal information from third-party business partners, such as social media sites, ad networks, and analytics providers.
• We collect personal information as described to you when we gather your information or as otherwise outlined in the CCPA.

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Disclosure of Personal Information for a Business Purpose
Three Pillar Partners LLC 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: Other entities affiliated with Three Pillar Partners LLC.
• Service Providers: When Three Pillar Partners LLC shares with a service provider, it enters into a contractual arrangement that describes the business purpose and requires the provider to both (a) keep that personal information confidential; and (b) not use it for any purpose except performing the obligations under the contract.
• Financial Institutions: Our sharing of your personal information with these entities is limited only to when you affirmatively direct us to share your personal information with these companies.

In the preceding twelve (12) months, Three Pillar Partners LLC 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
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The CCPA similarly requires Three Pillar Partners LLC to provide you with a statement on its personal information sales. The definition of “Sale” under the CCPA is very broad. Out of an abundance of caution, we are providing you with the below notice. In the preceding 12 months, we may have sold the below categories of information:

• 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.

Please note that the sale of personal information is limited to situations where you have affirmatively opted in to such sales. If you have any questions or concerns about the sale of your personal information, please contact us using the information provided in our Privacy Policy or California Privacy Notice.

Notice Regarding Your Rights

Access & Data Portability Rights

You have the right to request that Three Pillar Partners LLC 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, and unless an exception applies, we will delete (and direct our service providers to delete) your personal information from our records.

The CCPA provides several 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.
  

Right to Opt-Out of Sale of Personal Information
You have the right to request that Three Pillar Partners LLC no longer sell your personal information. To exercise that right, please click here: Do Not Sell My Personal Information or Calling us toll-free during business hours

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Three Pillar Partners LLC by:

• Filling out the California Consumer request form available at by clicking here.

Only you or someone registered with the California Secretary of State and legally authorized to act on your behalf may make a verifiable consumer request related to your personal information.
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 Three Pillar Partners LLC to verify, to a reasonable degree of certainty, that you are the person about whom Three Pillar Partners LLC collected personal information (or your authorized representative), which may include multi-factor authentication of identifying information provided by you. Such authentication may be conducted and verified independently or in combination with a comparison of personal information already maintained by Three Pillar Partners LLC if any; and
  
• Describe your request with sufficient detail that allows Three Pillar Partners LLC 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 that the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us, but we must also be able to confirm the personal information relates to you. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

Three Pillar Partners LLC endeavors to respond to a verifiable consumer request within forty-five (45) days of receiving it. If Three Pillar Partners LLC requires additional time to process your request, up to a maximum total of ninety (90) days from the date the request is received, we will notify you of this and inform you of the reason for requiring the additional time.

If you have an online account with us, we will deliver our written response to your online account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request or have denied a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

Three Pillar Partners LLC will not discriminate against you for exercising any of your CCPA rights as described above. Unless permitted by the CCPA, Guru Finance will not:

• Deny you goods or services.
  
• Describe your request with sufficient detail that allows Three Pillar Partners LLC to properly understand, evaluate, and respond to it.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We currently do not respond to Web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services.

We currently do not respond to DNT signals in browsers because we do not track individual users across the web.

May other parties collect personally identifiable information about an individual consumer’s online activities over time and across different websites when they visit www.PennieWise.co?

No.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits certain individuals that are California residents to request information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please email us at info@pillarfinancialrelief.com or write to us at Three Pillar Partners LLC, 5830 E 2nd St Ste 7000 Casper, WY 82609.

Changes to Our Privacy Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on our website and update the Notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

Contact Information

Three Pillar Partners LLC is committed to responding promptly to any questions or concerns you may have about this Notice. If you have questions concerning the methods by which Three Pillar Partners LLC collects or uses your personal information as explained in this Notice and our Online Privacy Policy, the rights granted to you under the CCPA, or how to exercise your rights, or if you are a consumer with a disability and you wish to receive a copy of this Notice, you can contact us by calling, writing, or emailing us:

Three Pillar Partners LLC
Phone: 833-339-3812
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 link. 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.