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CITADEL SERVICING CORPORATION D/B/A ACRA LENDING

CALIFORNIA EMPLOYMENT PRIVACY POLICY

This EMPLOYMENT PRIVACY POLICY, as defined by the California Privacy Rights Act effective January 1, 2023 (“CPRA”), (the “Act”), is adopted by Citadel Servicing Corporation d/b/a Acra Lending, its affiliates, and subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to its job applicants, employees, owners, directors, contractors, and other personnel residing in the State of California (“Consumer” or “you”).  In compliance with the Act, this Policy provides you with our business practices as to the categories of Personal Information we collect about you and the purposes for which it will be used and disclosed. All capitalized terms not defined herein shall have the same meaning as set forth in the Act.  We recommend that you retain a copy of this Privacy Policy for your records.

(Updated January 1, 2023)

Personal Information We Collect

We are committed to protecting the privacy and security of Personal Information. In the course of our business, we ask job applicants, prospective employees, and employees to provide necessary Personal Information relating to your employment or prospective employment. CSC will only collect and process your personal information in accordance with this Policy, unless otherwise required by applicable law.

We collect the following categories of Personal Information.

A. Unique Identifiers. A real name, alias, postal address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers and/or information obtained from pre-hire documents and websites such as job applications, resume, skillset, etc.

Unique personal identifier, online identifier, Internet Protocol address, cookies, beacon or other similar website related identifiers and/or information obtained from visiting web-based employment platforms.

YES
B. Personal information Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card 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.

Some personal information included in this category may overlap with other categories.

YES
C. Protected Classification Characteristics Age, 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. YES
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract 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. NO
F. Internet or other similar network activity. Browsing history, search history, information on your interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location, movements, and/or information obtained from your use of personal devices like fobs to access secure locations and systems. YES
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. YES
I. Professional or employment-related information. Current or past job history and other related information. YES
J. Non-public education information Education records directly related to when you were a student that are maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. YES
K. Inferences drawn from other personal information. Profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES

Personal Information does not include:

  • Publicly available information from federal, state, or local government records.
  • De-identified or aggregated consumer information.
  • Information exempted from the Act’s scope, like:
    • Personal Information covered by certain sector-specific privacy laws, including without limitation, the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994;
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), if applicable.

Sources of Personal Information

  • We obtain the categories of Personal Information listed above from the following categories of sources:
    • Directly from you and your authorized agents.
    • Indirectly from you and your authorized agents.
    • Directly from your activity on your assigned company equipment.
    • From service providers that help us provide employment-related services.
    • From third parties that interact with us in connection with our recruiting efforts.

Use of Personal Information

  • We may use or disclose the Personal Information we collect for one or more of the following business purposes:
    • To make an employment and/or job-related decision that involves you, including but not limited to, hiring and separation decisions.
    • To assess qualifications for a particular job or task, conduct performance reviews, determine performance requirements, gather evidence for disciplinary actions, and/or address grievances.
    • To manage working hours, appropriate labor environment, and improvement of work efficiencies.
    • To effectively process payroll and work-related claims.
    • To administer and maintain group health insurance benefits, benefits claims, 401K and/or retirement plans.
    • To provide you with information that you request from us.
    • To offer you company-sponsored discounts.
    • To communicate with you through email alerts and other notices concerning employee rights, benefits, events, or news.
    • To fulfill or meet the reason for which the information is provided. For example, if you provide us with emergency contact information in your application, we will use it to contact your designated person in case of an emergency.
    • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
    • To create and administer learning and development courses, including but not limited to training and educational seminars.
    • To comply with local, state, federal, and international laws and regulations, including but not limited to, requiring employers to maintain certain records.
    • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
    • As necessary or appropriate to protect the rights, property, or safety of us, our employees, and others.

    We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We do not sell your Personal Information.

We understand that sharing information with third parties is a big responsibility.  We are committed to only sharing information when needed for a legitimate business or legal purpose, and then only with recipients who will protect the data.  We only disclose your Personal Information to a third party for business purposes and only to the extent necessary to administer benefits, services, and/or conduct human resource activities.  When we disclose Personal Information for a business purpose, we enter into a written agreement that describes the purpose and requires the recipient to keep that Personal Information confidential and not use it for any purpose except performing the agreement.  We may disclose Personal Information to satisfy a legal or regulatory requirement, including responding to a subpoena or other lawful government request and will share only information that is necessary to comply with that requirement.  We may also share information if needed to enforce our legal rights, detect, or prevent fraud or security concerns, and protect public safety.  If we are involved in a merger, acquisition or any form of transfer or sale of some or all of our business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding we may share your Personal Information in connection with that transaction.

We disclose your Personal Information for business purposes to the following categories of third parties:

      • Our partners.
      • Service providers.
      • Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with your employment with the company.

Changes to Our Privacy Notice

      • We reserve the right to update this Employment Privacy Policy at our discretion and at any time. We will notify you when we make changes to this Employment Privacy Policy.  In the event that we would like to use your previously collected Personal Information for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your Personal Information for a new or unrelated purpose.  CSC may process your Personal Information without your knowledge or consent only where required by applicable law or regulation. Under CPRA requirements this policy will be reviewed and updated at least once every 12 months.

Your Privacy Rights

      • As a consumer (as defined above), you have the following rights under the CPRA:
        • The right to know, correct, and delete your personal information held by an employer or employer’s vendor on our behalf.
        • The right to opt out of the sale or sharing of your personal information by us or our vendors and/or restrict the use of your sensitive personal information.
        • The right to not be retaliated against for exercising the above rights.

Exercising Your Rights

      • To exercise your rights as described above, please submit a Verifiable Employee Request to us by:
        • Filling out the Employee Privacy Request Form per the Instructional Guide and a Third-Party Authorization Form, if applicable, here.
        • By visiting https://acralending.com/privacy-policy/
        • Emailing us at [email protected]

        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.

        You may only make a verifiable consumer request 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. Making a verifiable consumer request does not require you to create an account with us. 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 provide you with an acknowledgment of your request within ten days of your submission. We may contact you if we require additional information to process your request. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that 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, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

Contact Information

If you wish to make a Privacy Request exercising your Rights online, please fill out the form located here.

If you have any questions or comments about this policy, our Employee Privacy Policy, and the ways in which we collect and use your Personal Information, please do not hesitate to contact the HR Department or Legal Department at:

HR Department: [email protected]

Legal Department: [email protected]

Toll Free: 1-888-800-7761

Postal Address:

Citadel Servicing Corporation

25531 Commercentre Drive, Suite 160

Lake Forest, CA 92630

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