EQUAL HOUSING OPPORTUNITY STATEMENT

Whether you are a single property owner or managing a portfolio of 200 units, it is imperative for you and your team to grasp and adhere to the pertinent federal, state, and local fair housing laws. Your commitment to ensuring equal housing opportunity for all tenants and maintaining a compliant rental business is crucial.

The Fair Housing Act stands as the federal law prohibiting any form of discrimination based on a person's protected class when seeking housing, whether renting or buying a home, securing a mortgage, seeking housing assistance, or engaging in any housing-related activities. This significant piece of legislation was initially adopted as a part of the Civil Rights Act of 1968 and was further expanded in 1988 to encompass protections against discrimination based on disability and familial status.

EQUAL HOUSING OPPORTUNITY: DEFINED

Equal housing opportunity embodies the principle that all individuals should enjoy equal chances when it comes to selecting housing. This crucial legislation is administered and enforced by the Office of Fair Housing and Equal Opportunity (FHEO), an integral division within the U.S. Department of Housing and Urban Development (HUD). The Fair Housing Act of 1968 entrusted HUD with the vital role of enforcement.*

RENTAL DISCRIMINATION: AN OVERVIEW

Rental discrimination transpires when a landlord or property manager treats an applicant differently based on their inclusion in a protected class. The judiciary recognizes that discrimination can emanate from both intentional and unintentional actions.

Intentional discrimination, known as "disparate treatment" discrimination, occurs when an individual is subjected to adverse treatment due to their status in a protected class.

Unintentional discrimination, referred to as "disparate impact" discrimination, arises when a policy or action disproportionately affects members of a protected class, even without a deliberate intent to discriminate. The U.S. Supreme Court has recently affirmed the recognition of disparate impact liability under the Fair Housing Act. Consequently, landlords and property managers should be mindful that they may be held accountable for policies and practices that, even unintentionally, negatively impact individuals in protected classes. Often, such disparate impact liability is also acknowledged under state law. Therefore, landlords and property managers should thoroughly research state and local anti-discrimination laws to ensure compliance.

EXAMPLES OF RENTAL DISCRIMINATION

An instance of intentional discrimination is exemplified by displaying a sign stating, "No [insert protected class] need apply." While such overt discrimination is currently rare, other practices, such as imposing restrictions on families with children, still persist.

An illustration of unintentional discrimination may include a landlord or property manager applying a "one strike" tenant screening policy for arrests. According to HUD guidelines, as people of color are disproportionately arrested and being arrested may not correlate with one's ability to be a good tenant, such policies can disproportionately disqualify people of color from housing despite lacking any legitimate business justification.

PROTECTED CLASSES: WHO IS SHIELDED FROM RENTAL DISCRIMINATION

In the realm of fair housing, discrimination refers to differential treatment based on an individual's membership in a protected class. Beyond the federal fair housing laws, state and local regulations may offer additional protection to renters belonging to supplementary protected classes. Some of these are summarized below:

Protected classes under federal law include:

• Race

• Color

• Religion

• Sex, encompassing sexual orientation and gender identity

• National origin

• Familial status

• Physical or mental disability

State and local laws may extend protection to other categories, such as:

• Citizenship

• Age

• Veteran or military status

• Genetic information

• Sexual orientation

• Gender identity or expression

• Source of income (encompassing federal, state, or local rental-assistance programs, e.g., Section 8 housing choice vouchers and temporary rental assistance)

• Criminal history

ADDITIONAL CONSIDERATIONS: FAIR HOUSING GUIDELINES

Criminal History: In the spring of 2016, HUD issued guidance concerning the potential discriminatory impact of tenant screening based on criminal history.

Limited English Proficiency: While English proficiency is not an autonomous protected class under the Fair Housing Act, it is closely linked to national origin. Consequently, refusing to rent to someone due to a lack of English proficiency may constitute national origin discrimination.

Maximum Occupancy: Although the Fair Housing Act does not explicitly proscribe occupancy standards that limit the maximum number of occupants, some occupancy standards can inadvertently result in discrimination. It is crucial to exercise caution when establishing maximum occupancy limits for your rental property. Utilize the term "persons" when referring to occupants and refrain from expressly limiting the number of children. Consider not counting infants under the age of 1 as occupants.

It is recommended to consult with legal counsel to ascertain the existence of any additional local or state anti-discrimination laws applicable to your community.

DETERMINING MAXIMUM OCCUPANCY

Familiarize yourself with the relevant laws governing maximum occupancy, which may fluctuate based on square footage, bedroom size, and unit configuration. Some landlords and property managers adhere to the Keating Memorandum, a nationwide guideline for occupancy issued by HUD (63 Fed. Reg. 70255), while others abide by square footage guidance from the Building Officials and Code Administrators (BOCA) code.

Keating Memorandum:

• Two persons per bedroom, subject to specific exceptions and limitations. Housing providers must consider state or local laws establishing different standards, property size and layout, building system capacity, and the age of children.

BOCA Code:

• The unit must be at least 150 square feet for the first occupant.

• An additional 100 square feet is required for each additional occupant.

• Each room occupied for sleeping by one person must encompass at least 70 square feet of floor space, or at least 50 square feet per person if shared by more than one individual.

Whichever rule you adopt, it is vital to standardize and document the policy while acquainting yourself with pertinent state and local regulations.

RENTING TO FAMILIES WITH CHILDREN

Familial status, denoting a legally recognized relationship between an adult and a child under 18 residing in the household, stands as another protected class with distinctive considerations. With the exception of housing designed specifically for older persons, all properties should accommodate children. It is impermissible to discourage or deny renting to a family solely due to the presence of children under the age of 18.

EXEMPTIONS FROM FAIR HOUSING LAWS

Fair housing laws typically apply to both single-family homes and multifamily dwellings. Nevertheless, there may exist exemptions under the Fair Housing Act and state laws for landlords and property managers. While discriminatory advertising is perpetually illegal, there are specific federal law exemptions in limited circumstances, including situations where:

• An owner-occupied building comprises four or fewer units.

• Single-family houses are

• National Fair Housing Alliance

https://nationalfairhousing.org/

 

• U.S. Department of Housing and Urban Development

 

https://www.hud.gov/

 

Ask Raffucci Privacy Policy

Effective date: September 5, 2023

Introduction and Purpose

At Ask Raffucci, we're dedicated to guiding you through your financial journey by offering reliable and transparent financial insights and tools tailored to your needs. Your trust is paramount, and we prioritize maintaining the confidentiality of your personal financial data shared on our platforms. This Privacy Policy elucidates how your data is collected, utilized, shared, and protected when you interact with Ask Raffucci, its associated companies, service providers, partners, and other relevant stakeholders.

Extent of this Privacy Policy

This Policy encompasses all interactions with products and solutions offered by Ask Raffucci, Inc. and its subsidiaries, inclusive of Fundera, Inc. (“Ask Raffucci Services” or “Services”). This includes interactions on our web portals, for instance, www.askraffucci.com, and any mobile applications affiliated with Ask Raffucci (collectively referred to as the “Platform”).

Engaging with our Services signifies your acceptance of the privacy measures detailed in this Policy.

Primarily, our data practices are shaped by the Gramm-Leach-Bliley Act. Refer to our Gramm-Leach-Bliley Privacy Notice for detailed insights into the privacy options corresponding to our Services. Any terms that remain undefined in this Privacy Policy hold the meaning ascribed in the Ask Raffucci Terms of Use.

I. Data Collection Practices

A. DATA SOURCED DIRECTLY FROM USERS

Your direct interactions with our Services, such as account creation, service inquiries, accessing your credit report, linking external financial accounts, or utilizing tools and forms on our Platform, may require you to share specific information:

• Full Name.

• Contact email.

• Residential address.

• Telephone number.

• Birth date.

• Social Security details.

• Authentication data like username and password.

• Details of external financial accounts.

• Personal financial specifics, including assets, liabilities, income, and more.

• Employment or business details.

• Demographic specifics, especially when pertinent to a financial offering you're exploring (like auto insurance quotes or retirement calculators).

• Any communication records, encompassing emails, calls, or other modes (phone call recordings might be stored, subject to legal permissions).

Note: We never retain login details for your external financial accounts. We securely transmit this data to our associated partners for identity validation, product prequalification, or to fetch your financial data for our Platform.

B. DATA GATHERED AUTOMATICALLY

• Details Accumulated

Our system may automatically detect and record specific data when you interact with our Platform, read emails from Ask Raffucci, or utilize our Services. This data might include:

• Device or IP addresses.

• Browser or device model.

• Location details, especially from mobile devices.

• Device configurations and software details.

• Websites visited immediately before or after our Platform.

• Your activity on our Platform, including pages accessed, and any clicks or interactions.

• Path taken to arrive at, navigate through, and depart from our Platform.

• Timestamps of your interactions with our Services.

C. Information from External Sources

We may gather data about you from external entities, such as our business collaborators, referrers, or advertisers. Upon your request, we may also procure credit reports or scores from credit reporting agencies like TransUnion, Experian, or Equifax, or from third-party platforms that allow data sharing using application interfaces like Facebook Connect or Twitter API. Any information merged with the data we collect via our Services will be handled as per this Privacy Policy, our Terms, and the prevailing law.

• Account Integration Feature

• This feature lets you monitor all your external financial accounts on our platform. By using this feature, you grant us and our third-party associate, Plaid, Inc., access to the financial accounts you specify. We might utilize this data to assess your eligibility for other services, recommend relevant products, or refine our offerings. Utilizing this feature means you accept Plaid's User Privacy Policy.
   

• Tax Collaboration

• Using the tax service, powered by Column Tax, will allow us to access specific details about your tax filing, such as filing status, filing jurisdictions, residential state, and tax amount payable or refundable. You authorize Column Tax and its handlers to share this data with us for the purposes detailed ahead.
   

II. Utilization of Your Details

Your data is pivotal for our functioning. We utilize it to:

A. Deliver the Services you seek and facilitate third parties to offer more to you.

B. Upgrade and enhance the Services and introduce new aspects.

C. Track and understand user behavior and device preferences.

D. Detect fraudulent activities and maintain data security.

E. Employ your email or personal details to (a) communicate for administrative reasons, (b) address content-related concerns like intellectual property or privacy, and/or (c) send you promotional content, offers, or updates linked to the Services and our affiliates. Typically, you have the choice to unsubscribe from promotional messages via links in the emails, by adjusting your account settings, or by reaching us directly at Please@askraffucci.com

F. Leverage Cookie data and automatically sourced details to (a) tailor our services, for instance, remembering your inputs so you're not prompted repeatedly; (b) auto-populate forms; (c) deliver personalized ads and content across devices; (d) assess the efficiency of the Services and marketing tactics of third parties; (e) analyze aggregated metrics such as visitor count and page views; and (f) track your actions and status in promotions or other ventures.

G. If you seek your consumer credit reports, we might use them (1) to grant you access to your free credit score, including periodic updates, and (2) to suggest financial products or services that might interest you, such as credit cards or loans, from our partners.

 

III. Disclosure of Your Data

A. In the process of delivering our Services and managing our business, your information might be disclosed. For instance, personal details like name, email, address, and Social Security number might be shared with third-party services to authenticate your identity related to specific Services, such as viewing your credit score.

B. We might disclose information you provide to third-party lenders or services associated with specific Services, including:

• Pre qualification requests for third-party credit or loans.

• Requests for detailed or tailored data on financial offers from our third-party partners.

• Credit report or score access requests.

• Access requests for third-party financial accounts.

• Product or third-party lender complaints.

• Seeking advice via our Services; we might share some of your details with external experts and consultants.

• C. Exiting our platform to a third-party site (e.g., from a rate table) may involve sharing anonymized details like IP addresses with third-party partners.

• D. We might share credit reports and personal data with our NerdWallet subsidiaries to recommend financial products of potential interest.

• E. Third-party services assisting our operations might receive your information but are bound contractually to confidentiality. Such cases include:

• Website and application-related services.

• Marketing tasks, including emails and promotional content delivery.

• Fraud prevention and security.

• F. Public sections of the Site where you share information make it accessible to all viewers, including other users.

• G. Anonymized analytics about user interactions with our Services might be shared with third-party partners.

• H. We might disclose data if legally required or based on a genuine belief of it being necessary to obey the law or cooperate with legal processes.

• I. By using our Services, you agree to disclose your details to third parties. Their use of your information follows their own policies, over which we have no control.

• J. Post-request submission via our Services might lead to third parties contacting you directly, including through telemarketing, even if you're registered on Do Not Call lists.

• K. If you wish to avoid the above-mentioned sharing, refrain from submitting service or information requests. Once a request is made, third-party policies govern the use of the shared information.

• L. Declining information sharing might limit the Services we can offer you.

• M. Post request submission, you can decline any free consultations or service offers.

• N. In events like mergers, acquisitions, or asset sales, personal information may be disclosed or transferred as part of the transaction.

• O. For more details on your sharing options, refer to our Gramm-Leach-Bliley Privacy Policy.

• P. Tax services provided by Column Tax have their own privacy policy. Interacting with Column Tax via our app or linking accounts means you consent to share data with them. The data shared, either directly or indirectly, will be governed by Column Tax’s privacy norms and terms.

IV. Managing Your Data and Membership with Ask Raffucci

A. EXERCISING YOUR DATA RIGHTS

• Understanding Your Rights
  We acknowledge your entitlement to your personal details, even without an Ask Raffucci account. The extent of your rights related to the data we gather may vary based on your residence. For more details on exercising these rights, navigate to our Privacy Preferences page. For funding concerns, refer to our Funding Privacy Preferences page.
   

• Verification Process
  Ensuring the security of your data is paramount. Hence, we might request supplementary details to validate your identity or claim to the data. If verification fails, you might need to provide adequate documentation for us to honor your data rights.
   

• Data Retention Policy
  Unless a deletion request is received, we retain your data to fulfill our obligations and effectively conduct business. However, despite deletion requests, we might keep your information to:

  • Comply with legal and regulatory mandates.

  • Address, assert, or defend legal rights.

  • Prevent deceptive or harmful activities on our platform.

• Different sets of data might be stored for varying durations. Dormant accounts risk data deletion. Technical or legal reasons might prevent complete data erasure. In such cases, we'll safeguard your data from further processing until its eventual deletion or anonymization.
   

B. MODIFYING YOUR DETAILS

• Updating Ask Raffucci Details
  After registering with Ask Raffucci, you can modify your profile and preferences anytime via the site’s account settings.
   

• Modifying Funding Information
  If you've sought a loan with us, you can access or correct submitted details via your user profile. For corrections, reach out to support@ourfundingdomain.com. Even post deregistration, we might preserve specific details as per the law.
   

C. ACCOUNT DEACTIVATION

Deactivating your account doesn’t erase your data. Although we promptly reflect deactivation in our records, your data might be retained for reasons like legal compliance and fraud prevention. Post-deactivation, you'll cease to receive our emails, and links to third-party accounts and services will terminate.

D. OPTING OUT OF COMMUNICATIONS

• Email Unsubscription
  To avoid receiving promotional emails or newsletters, use the unsubscribe option at any marketing email's end. Despite opting out, we may store your data for various reasons, including fraud prevention and data backups.
   

• SMS Unsubscription
  Registered funding users might receive SMS alerts related to their activities. To opt out, text "STOP" to 646-760-3048. To seek assistance, text "HELP" to the same number or reply HELP to any of our messages. Upon your HELP request, we'll provide STOP guidelines and share links to relevant service terms and privacy policies.

V. Safeguarding Your Data

At Ask Raffucci, we implement a combination of physical, administrative, and digital measures crafted to uphold the confidentiality and security of your data. However, we cannot guarantee or assert the complete security of data you share with us via the Services or stored on our platform. Such actions are at your discretion and risk.

VI. Rights of California Residents

This segment provides information as stipulated by the California Consumer Privacy Act (“CCPA”) and is relevant to "personal information" governed by this law. While the majority of our data practices are directed by our Gramm-Leach-Bliley Privacy Notice, Californian residents should note that the CCPA might be applicable to our Services when related to business offerings showcased on our website (e.g., corporate credit cards and business loans). Refer to our California Privacy Notice for detailed disclosures relevant to California and details on exercising your CCPA rights.

VII. For Global Users

Ask Raffucci’s Services are based and hosted in the United States and cater solely to users within this region. The content we offer and third-party services featured are exclusively tailored for the U.S. market. If you access the Services from regions outside of the U.S., you consent to transferring your data to the U.S. for both storage and processing.

VIII. Protecting Minors

The Services are inaccessible to children under 13. We neither target nor consciously gather personal data from children below this age. Should we identify any unintentional collection of data from such a child, we will take feasible steps to delete it from our records. If you’re a guardian or parent of a child below 13 who has shared personal data with us, get in touch via the contact details provided below to seek its removal.

IX. In Case of Organizational Changes

Ask Raffucci holds the authority to transfer or delegate user data we’ve acquired in scenarios like corporate activities: potential mergers, consolidations, acquisitions, or if bankruptcy arises.

X. Modifications to this Privacy Notice

We maintain the discretion to revise this Privacy Notice whenever necessary. Significant alterations in our data practices will be communicated to you, either via a noticeable alert on our platform or through email, allowing you to decide on continued Service usage. Important changes come into effect 30 days post our initial alert or once you approve the altered conditions. Minor changes are effective once the revised Privacy Notice or Service Terms are posted. We encourage periodic revisits to this page to stay updated on any Privacy Notice amendments. Any disagreements will be settled based on the Privacy Notice active when the disagreement originated.

XI. Get in Touch

For queries or feedback regarding this Privacy Notice, data protection, our data practices, or your choices, please email us at privacy@askraffucci.com.

Ask Raffucci, Inc.

ADDRESS

POBOX

We appreciate your time in understanding our Privacy Notice.

​

Ask Raffucci California Privacy Notice

Effective Date: Oct. 20, 2023

This document, titled the "California Privacy Notice," addresses requirements stipulated by the California Consumer Privacy Act (“CCPA”). It focuses specifically on “personal information” as described under the CCPA. While our primary data practices are influenced by our Gramm-Leach-Bliley Privacy Notice, for Californian residents, the CCPA might be relevant to our offerings, especially when linked to business-centric products we display (like corporate credit cards or business loans). It’s essential to consider this California Privacy Notice in parallel with the Ask Raffucci Privacy Notice and Ask Raffucci Terms of Service, both of which are integrated here by implication.

A. Categories, Utilization, and Sharing of Personal Data We Obtain

We acquire various personal data categories about California consumers, as detailed below. This information is utilized and shared with third parties for legitimate business or commercial reasons. Like many digital companies, we authorize select third-party entities, inclusive of unrelated business collaborators, ad networks, analytics services, and other advertisement providers, to collect data about your online interactions directly, spanning various browsers and devices. This is achieved using technologies like cookies, web beacons, and mobile ad identifiers. These third parties might utilize this data to present tailored online ads to you, spanning devices and browsers, gauge ad campaign efficiency, analyze website activity, counteract fraud, or for their independent business and commercial objectives. Certain third-party data gathering might be considered a “sale” of personal data under the CCPA. For a comprehensive understanding of these practices, consider reading the "Third-Party Tracking and Buttons" segment of the Ask Raffucci Privacy Notice. To learn more about opting out of data sharing that might be classified as a sale under the CCPA, refer to the "Your Rights Regarding Personal Information" section 

 

Ask Raffucci: Overview of Personal Information Categories

Categories of Personal Information

Sources of Collection

Purposes for Collection, Use, and Sharing

Disclosed to Third Parties For Business Purposes

Personal and online identifiers (e.g., name, email, unique online IDs)

All sources detailed below.

All reasons detailed below.

All parties detailed below.

Sensitive Personal Data (e.g., Social Security number, bank details)

All sources detailed below.

All reasons detailed below.

All parties detailed below.

Characteristics protected under CA or federal law (e.g., age, gender)

All sources detailed below.

All reasons detailed below.

All parties detailed below.

Commercial or transactional data (e.g., services purchased via us)

All sources detailed below.

All reasons detailed below.

All parties detailed below.

Internet or other electronic activity (e.g., sites visited before/after our site, interactions with our Services)

All sources detailed below.

All reasons detailed below.

All parties detailed below.

Geolocation data

All sources detailed below.

All reasons detailed below.

All parties detailed below.

Professional or employment data

All sources detailed below.

All reasons detailed below.

All parties detailed below.

Educational data

All sources detailed below.

All reasons detailed below.

All parties detailed below.

Predictive inferences from the data above

All sources detailed below.

All reasons detailed below.

All parties detailed below.

Additional data linked to the personal info above

All sources detailed below.

All reasons detailed below.

All parties detailed below.

 

Note: Specifics on "All sources detailed below," "All reasons detailed below," and "All parties detailed below" would be provided in subsequent sections or tables for clarity.

​

Ask Raffucci: Detailed Information on Personal Data Collection and Your Rights

B. Source Categories of Data Collection

We obtain personal information directly from you. Additionally, upon your instruction, we can access credit reports or scores from credit bureaus like TransUnion or Equifax, or from third-party platforms that offer the capability to share information you've given to them using tools like application program interfaces (APIs), such as Facebook Connect or Twitter's API. You may also guide and authorize us to gather personal details from your financial accounts held at other external financial entities. We also employ automated tools to gather specific information about you, like how you engage with our Services, as highlighted in this policy.

C. Purposes for Gathering, Utilizing, and Sharing California Resident Data

The personal details we gather are utilized and disclosed for our commercial and operational purposes, as elaborated in this Privacy Policy.

For commercial objectives, this includes activities like: marketing, promotional endeavors, verifying identity, preventing fraud, service delivery, and meeting customer demands.

Operational purposes, as delineated in the CCPA, encompass: conducting audits; ensuring legal adherence; safeguarding against security threats, fraud, and unlawful activities; rectifying service and system issues; administrative tasks such as managing orders and payment processing; analytics; internal studies and operations; enhancing our Services; and other specific uses.

We share the above-mentioned categories of personal information with entities such as: service facilitators, loan partners, affiliate partners, collaborative marketing allies, credit bureaus, financial data aggregators, governmental bodies, promotional networks, online service providers, analytics services, operating system vendors, professional consultancy agencies, and social media platforms.

Additionally, we permit some external parties to gather data about your interactions on our website through third-party cookies. This data might be used by these entities to showcase targeted ads based on your behaviors across multiple devices or for assessing advertising campaigns.

D. California Resident Rights Pertaining to Personal Data

If you reside in California, you are entitled to particular rights concerning your personal data, albeit with some exceptions and restrictions:

• For some types of personal data, the right to inquire about the data (if any) we shared with third parties for their direct promotional activities during the last year, and the identification of these third parties.

• The right to be informed about the types and specific pieces of personal information we gather, utilize, disclose, or potentially sell; where we source this data; the reasons for collecting or potentially selling this data; categories of personal data we've disclosed or potentially sold for operational purposes; and third parties we've engaged in these transactions with.

• The right to request the deletion of your personal data we've gathered.

• The right to data portability, allowing you to retrieve and repurpose CCPA-covered personal data for your own needs.

• The right to limit the utilization of your sensitive personal data to specific allowed purposes.

• The right to rectify any incorrect personal data we possess about you.

• The right to decline our selling or sharing of your personal data.

• The right to not be subjected to discrimination for invoking your CCPA-endowed privacy rights.

 

Ask Raffucci: Personal Data Retention and Exercising Your Rights

E. Retaining Your Personal Data

Unless we receive a specific request from you to remove your personal data, we will keep it for as long as necessary to fulfill our data storage obligations, offer you the Services you've sought, and to effectively manage our business operations. Even after a deletion request, we might need to hold on to your data for purposes such as:

• Meeting legal or regulatory compliance (e.g., holding onto records of interactions you've had with us);

• To assert, establish, or defend against legal actions; and/or

• To safeguard against any fraudulent or malicious actions on our Services.

Different data might be stored for varied durations. For dormant accounts, we might remove the data immediately. There could be times when completely erasing, anonymizing, or de-identifying your data is not possible due to technical, legal, or operational reasons. In such situations, we commit to taking all reasonable steps to prevent any further processing of your personal data until it can be erased, anonymized, or de-identified.

F. Executing Your California Consumer Rights

To Invoke Your Right to Request, Know, or Delete:

To use your rights as a California consumer to request, be informed, or delete, kindly visit our Privacy Preferences section. Additionally, you can initiate a CCPA request by:

• Emailing us at privacy@askraffucci.com with "CCPA Request" as the subject and detailing the specific right in the email's body, or

• Heading to https://support.askraffucci.com, clicking “Submit a Query”, choosing “Other Queries or Concerns” from the options, and sending it with “CCPA Request” in the subject along with the specific right you're referring to in the message.

To Decline the Sale or Sharing of Personal Information:

If third-party data collection on our website is interpreted as selling or sharing personal data, we'll guide you on how to decline specific cookie-associated data collection methods.

On select websites, you can dictate your cookie preferences using a cookie management interface. On our other platforms, users have the options to:

• Use privacyrights.info to decline the sale of this kind of personal data by third-party entities that are part of the DAA’s CCPA Opt-Out Program.

• Visit myaccount.google.com/data-and-personalization, navigate to the “Ad customization” section, select "Go to ad settings" and disable "Ad customization".

• Refer to the "Third-Party Web Beacons and Third-Party Buttons" segment in the Ask Raffucci Privacy Policy to decline interest-driven ads and other cookie-associated data collection methods.

For exercising other CCPA rights, please access our Privacy Preferences section or head to https://support.askraffucci.com, click “Submit a Query”, choose “Other Queries or Concerns” from the options, and send it with “CCPA Request” in the subject along with the specific right you're referring to in the message.

 

Ask Raffucci: Verification and Rights Procedures

G. Process and Information Needed for Verification

Please be aware that for us to confirm your identity or to grasp the extent of your request, we might need to obtain more details from you. You don't have to set up an account with us to make a request or get a response. We'll ask you for details that we already hold for the purpose of verifying your identity. There might be situations where we can't proceed with a request for information or its deletion, especially if we can't confirm your identity.

H. Representation by an Authorized Entity

You can assign a representative to make a CCPA application for you by contacting us using the details mentioned earlier. If we can't verify your identity when you make the assignment, we might ask for more details. Do note, if you're appointing an organization to act on your behalf, the CCPA mandates that this organization be registered with the California Secretary of State.

I. Protection for Minors

We don’t engage in selling personal data of individuals we know to be younger than 16.

J. Details Pertaining to Small Business Loans

Occasionally, you might share your personal details with us intending to apply for small business loans through one or more of our associates. You consent that sharing your personal details in relation to your application doesn't constitute a sale of your personal details as per the CCPA.