Privacy Policy

Section 01

Who We Are

Premium Capital California, Inc. ("Company," "we," "us," or "our") is a credit repair organization and financial services company incorporated and operating under the laws of the State of California, United States of America.

We provide credit repair, FCRA-based dispute services, legal referrals, business funding consultation, and debt settlement strategy to consumers across the United States. Our Services are exclusively available to residents of the United States.

Section 02

Scope & US Applicability

This Privacy Policy applies exclusively to consumers located in the United States of America. Our Services are not offered to, marketed to, or intended for use by individuals outside the United States.

By accessing our website, scheduling a consultation, or engaging our Services, you confirm that you are a United States resident and that you have read and agree to this Privacy Policy in its entirety.

This policy is governed by and construed in accordance with federal United States law and the laws of the State of California, including but not limited to:

• The Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681 et seq.
• The Credit Repair Organizations Act (CROA), 15 U.S.C. § 1679 et seq.
• The California Consumer Privacy Act (CCPA), Cal. Civ. Code § 1798.100 et seq.
• The California Privacy Rights Act (CPRA)
• The Gramm-Leach-Bliley Act (GLBA) financial privacy provisions
• The Federal Trade Commission Act, 15 U.S.C. § 45
• The Telephone Consumer Protection Act (TCPA)

Section 03

Information We Collect

We collect information you provide directly and information collected automatically when you use our Services.

Information You Provide Directly

• Full legal name, date of birth, and current US address
• Email address and US phone number
• Social Security Number — last four digits only, used exclusively for dispute letter identification as required by the FCRA and CROA
• Credit reports and credit scores obtained through authorized third-party monitoring services or provided directly by you
• Creditor account numbers, balances, and status information appearing on your credit reports
• Financial information relevant to business funding applications
• Appointment scheduling details and consultation notes
• All communications with our team via email, phone, SMS, or web forms

Information Collected Automatically

• IP address and approximate geolocation (country, state, city)
• Device identifiers, browser type, and operating system
• Referring URLs and exit pages
• Pages visited, time on page, and click behavior
• Cookie and tracking pixel data (see Section 7)

Section 04

How We Use Your Information

We use the information we collect solely to provide, operate, improve, and communicate about our Services. We use your information to:

• Prepare, send, and track credit dispute letters to Equifax, Experian, and TransUnion on your behalf under FCRA authorization
• Identify potential FCRA violations and refer qualifying cases to our legal partners with your consent
• Analyze your full credit profile and build a personalized dispute and recovery strategy
• Schedule and conduct consultations, follow-ups, and case reviews
• Communicate with you via email, phone, and SMS regarding your case status, appointments, and account updates
• Connect you with business funding partners when your credit profile meets qualification thresholds
• Facilitate debt settlement negotiations and payoff strategies
• Comply with our obligations under FCRA, CROA, GLBA, CCPA/CPRA, and all other applicable federal and state laws
• Detect and prevent fraud, unauthorized access, and abuse of our Services
• Enforce our agreements, including this Privacy Policy and any Terms of Service
• Defend against legal claims and exercise our legal rights

Section 05

How We Share Your Information

We limit sharing of your personal information to what is strictly necessary and legally authorized.

• Credit Bureaus (Equifax, Experian, TransUnion): Pursuant to your written FCRA authorization to file disputes on your behalf.
• FCRA Legal Partners: Including McCarthy Law PLC, when your file qualifies for litigation, only with your explicit written consent. These partners are bound by attorney-client privilege, bar ethics rules, and their own privacy policies.
• Business Funding Partners: Only upon your explicit opt-in authorization for funding services.
• Debt Settlement Partners: Only with your explicit consent for debt negotiation services.
• Service Providers: Third-party vendors operating on our behalf — including GoHighLevel (CRM/scheduling), email delivery platforms, and SMS providers — under written data processing agreements that prohibit independent use of your data.
• Credit Monitoring Services: MyFreeScoreNow.com, when you authorize account access for report integration.
• Legal Compliance: When required by valid legal process, court order, subpoena, or government authority under applicable United States law.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, with advance notice to you and continued protection of your data under terms no less protective than this policy.

Section 06

Credit Reports & Financial Data

As a credit repair organization regulated under the FCRA and CROA, we handle some of the most sensitive personal data that exists. We treat this data under the strictest standards required by federal law.

FCRA Authorization: We only access, review, or act on your credit report data pursuant to a valid written authorization signed by you. You may revoke this authorization at any time in writing, though revocation will end our ability to provide Services to you.

Preferred Credit Monitoring: We work with MyFreeScoreNow (www.myfreescorenow.com) as our preferred third-party credit monitoring partner. Their service integrates directly with our analysis system and provides real-time access to all three bureau reports. MyFreeScoreNow is a separate entity and operates under its own privacy policy and applicable federal consumer financial protection laws.

Alternative — No Account Required: Clients who prefer not to create a monitoring account may obtain their free annual credit reports from all three bureaus at www.annualcreditreport.com — the only federally authorized free credit report source under the FACT Act — and submit them to us directly by email.

SSN Policy: We collect and use only the last four digits of your Social Security Number, solely for the purpose of identifying you in dispute correspondence as required under the FCRA. Full SSNs are never requested, collected, or stored by Premium Capital California.

Storage & Access Controls: All credit and financial data is stored in encrypted systems. Access is restricted to authorized personnel directly assigned to your case. Data is never stored on personal devices.

Section 07

Cookies & Tracking Technologies

Our website uses cookies and tracking technologies for operational and analytical purposes.

• Essential Cookies: Required for website functionality. Cannot be disabled without impairing service.
• Analytics: Tools such as Google Analytics help us understand traffic patterns and improve our site. Data is aggregated and does not identify individual users.
• Advertising Pixels: We may use the Meta (Facebook) Pixel to measure advertising campaign effectiveness. These pixels collect standard event data (page views, button clicks) but do not collect your name, SSN, credit information, or any sensitive financial data.

You may control cookies through your browser settings. You may opt out of Meta's ad tracking through your Facebook account settings or at www.youronlinechoices.com. You may opt out of Google Analytics at tools.google.com/dlpage/gaoptout.

Section 08

Data Retention

We retain personal information only as long as necessary to fulfill our service obligations and comply with applicable US law.

• Active client files: Duration of engagement plus 3 years post-completion (CROA compliance)
• Dispute correspondence records: Minimum 5 years (FCRA and CROA requirements)
• Financial and funding records: 7 years (consistent with IRS and banking record retention standards)
• SMS/email consent records: 4 years from date of consent (TCPA compliance)
• Consultation records: 2 years from date of consultation
• Arbitration-related records: Indefinitely or until final resolution of any dispute, whichever is later
• Lead/prospect data: 12 months from initial contact unless a service relationship is established
• Technical/usage data: 13 months

Upon expiration of the applicable retention period, data is securely deleted using industry-standard data destruction methods or irreversibly anonymized.

Section 09

Data Security

We implement administrative, technical, and physical safeguards designed to protect your personal information consistent with applicable US federal and state security standards.

• All data transmitted via our Services is encrypted using TLS 1.2 or higher
• Sensitive data at rest is stored in AES-256 encrypted systems
• Access to client files is strictly role-based and limited to personnel directly assigned to your case
• Multi-factor authentication is required for all internal systems containing personal data
• Third-party service providers are contractually required to maintain equivalent security standards
• We conduct periodic security reviews and vulnerability assessments

Section 10

Your Rights & Choices

As a US consumer, you have the following rights with respect to your personal information. We will respond to all verified requests within 30 days with no charge for reasonable requests.

• Right to Access: Request a copy of the personal information we hold about you
• Right to Correction: Request correction of inaccurate or incomplete information in our records
• Right to Deletion: Request deletion of your personal information, subject to legal retention obligations under FCRA, CROA, and applicable state law
• Right to Data Portability: Receive your personal data in a structured, commonly used, machine-readable format
• Right to Withdraw Consent: Revoke FCRA authorization to access your credit data at any time in writing
• Right to Opt Out of SMS: Reply STOP to any text message to immediately opt out of SMS communications
• Right to Opt Out of Email: Click the unsubscribe link in any marketing email
• Right to File a Complaint: Lodge a complaint with the CFPB at consumerfinance.gov, the FTC at ftc.gov/complaint, or your state Attorney General

To exercise any right, email [email protected] with subject line "Privacy Rights Request — [Your Full Name]." We will verify your identity before processing any request.

Section 11

California Privacy Rights (CCPA / CPRA)

California residents have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), effective January 1, 2023.

Categories of Personal Information Collected

In the preceding 12 months, we have collected the following CCPA categories: Identifiers; Personal records (Cal. Civ. Code § 1798.80); Financial information; Internet or network activity; Inferences drawn from personal information.

Your California Rights

• Right to know what personal information is collected, used, shared, or sold
• Right to delete personal information we have collected about you
• Right to correct inaccurate personal information
• Right to opt out of the sale or sharing of personal information — we do not sell or share personal information for cross-context behavioral advertising
• Right to limit use of sensitive personal information
• Right to non-discrimination for exercising CCPA rights

Shine the Light (Cal. Civ. Code § 1798.83)

California residents may request information about disclosures of personal information to third parties for direct marketing purposes. We do not disclose personal information to third parties for their direct marketing use.

Submit California privacy requests to [email protected] with subject line "California Privacy Rights — CCPA Request." Response within 45 days as required by law.

Section 12

Children's Privacy

Our Services are directed exclusively to adults aged 18 and older residing in the United States. We do not knowingly collect, solicit, use, or disclose personal information from any person under 18 years of age.

If we discover that we have inadvertently collected personal information from a minor under 18, we will delete such information immediately. If you believe a minor has provided us with personal information, contact us at [email protected] immediately.

This policy is consistent with the Children's Online Privacy Protection Act (COPPA), 15 U.S.C. § 6501 et seq.

Section 13

Third-Party Links & Services

Our website and communications may contain links to the following third-party services. We are not responsible for their privacy practices.

• MyFreeScoreNow (myfreescorenow.com) — credit monitoring integration partner
• AnnualCreditReport.com — federally authorized free credit report source under the FACT Act
• McCarthy Law PLC — FCRA litigation partner
• GoHighLevel — CRM and appointment scheduling platform
• Meta (Facebook) — advertising and analytics
• Business funding and financial service partners (disclosed at time of referral)

We encourage you to review the privacy policy of any third-party site you access through our platform. The presence of a link does not constitute our endorsement of that site's privacy practices.

Section 14

Governing Law & Jurisdiction

This Privacy Policy and any disputes arising from it shall be governed by and construed in accordance with the laws of the State of California and applicable federal United States law, without regard to California's conflict of laws provisions.

Subject to the Binding Arbitration Agreement in Section 15, you consent to the exclusive personal jurisdiction of the state and federal courts located in Orange County, California for any action not subject to arbitration.

This policy is not intended to and does not create any rights under the laws of any jurisdiction outside the United States.

Section 15

Binding Arbitration Agreement

Agreement to Arbitrate

You and Premium Capital California agree that any dispute, claim, or controversy arising out of or relating to this Privacy Policy, our Terms of Service, or your use of our Services — including questions about the existence, validity, interpretation, breach, or termination of this agreement — shall be resolved exclusively by binding individual arbitration administered by the American Arbitration Association (AAA) under its Consumer Arbitration Rules, rather than in any court of law.

Scope of Arbitration

This arbitration agreement covers all claims arising under federal law, California law, or any other applicable state law, including but not limited to claims under the FCRA, CROA, CCPA, TCPA, and any common law claims for breach of contract, fraud, misrepresentation, or negligence related to our Services or this Privacy Policy.

Arbitration Process

• Administrator: American Arbitration Association (AAA) — www.adr.org
• Rules: AAA Consumer Arbitration Rules, available at www.adr.org/consumer
• Location: Arbitration shall be conducted in Orange County, California, or via videoconference at either party's election
• Arbitrator: A single, neutral arbitrator selected pursuant to AAA Consumer Arbitration Rules
• Costs: Filing fees shall be allocated per AAA Consumer Arbitration Rules. For claims under $10,000, we will pay all AAA filing, administration, and arbitrator fees if you are the claimant
• Award: The arbitrator may award any relief that a court could award, including injunctive or declaratory relief, attorneys' fees, and costs. The arbitrator's decision is final and binding and may be entered as a judgment in any court of competent jurisdiction

Pre-Arbitration Notice Requirement

Before initiating arbitration, you must provide us with written notice of your claim by emailing [email protected] with the subject line "Notice of Dispute." The notice must include your name, address, a description of the dispute, and the relief you seek. We will have 30 days to attempt to resolve the dispute informally. If unresolved, either party may then initiate arbitration.

Exceptions to Arbitration

The following claims are excluded from arbitration and may be brought in small claims court or as otherwise permitted by law:

• Claims within the jurisdiction of small claims court (typically under $10,000 in California)
• Claims for injunctive or equitable relief to protect intellectual property rights
• Any claim that applicable law expressly excludes from mandatory arbitration

Section 16

Class Action Waiver

To the fullest extent permitted by applicable law, you waive your right to bring or participate in any class action lawsuit, class-wide arbitration, private attorney general action, or any other consolidated or representative proceeding against Premium Capital California, its officers, directors, employees, agents, or affiliates.

The arbitrator in any arbitration proceeding shall have no authority to consolidate or join claims of multiple parties, or to otherwise preside over any form of representative, collective, or class proceeding.

If a court of competent jurisdiction determines that any portion of this class action waiver is unenforceable, the remaining provisions of this waiver shall remain in full force and effect. If the entire class action waiver is found unenforceable, then the arbitration agreement in Section 15 shall be null and void with respect to that claim only, and that claim shall proceed in a court of competent jurisdiction.

Section 17

Limitation of Liability

To the maximum extent permitted by applicable United States law, Premium Capital California's total liability to you for any claims arising from this Privacy Policy or your use of our Services shall not exceed the greater of: (a) the total amount paid by you to Premium Capital California in the 12 months preceding the claim; or (b) one hundred dollars ($100.00).

In no event shall Premium Capital California be liable for any indirect, incidental, special, consequential, punitive, or exemplary damages, including but not limited to lost profits, loss of data, loss of goodwill, or service interruption, even if advised of the possibility of such damages.

Some states do not allow the exclusion or limitation of incidental or consequential damages. In such states, our liability is limited to the maximum extent permitted by applicable law.

Nothing in this section limits our liability for: (a) gross negligence or willful misconduct; (b) fraud or fraudulent misrepresentation; or (c) any liability that cannot be excluded or limited under applicable US law, including consumer protection statutes such as the FCRA and CROA.

Section 18

Changes to This Policy

We reserve the right to modify this Privacy Policy at any time. When we make material changes, we will:

• Update the Effective Date at the top of this page
• Notify active clients by email at least 30 days before material changes take effect
• Post a prominent notice on our website homepage
• For changes to the arbitration agreement, provide an additional 30-day opt-out window

Your continued use of our Services after the effective date of any changes constitutes your acceptance of the revised Privacy Policy. If you do not agree to the revised policy, you must discontinue use of our Services and notify us in writing.

Section 19

Contact & Dispute Notice

For all privacy inquiries, rights requests, or dispute notices, contact us using the information below. Failure to use the correct subject line may delay our response.

• Company: Premium Capital California, Inc.
• Email: [email protected]
• Privacy Inquiries Subject Line: "Privacy Policy Inquiry — [Your Name]"
• Rights Requests Subject Line: "Privacy Rights Request — [Your Name]"
• Dispute Notice Subject Line: "Notice of Dispute — [Your Name]"
• Arbitration Opt-Out Subject Line: "Arbitration Opt-Out — [Your Name]"
• Response Time: 5 business days for general inquiries; 30 days for rights requests; 30 days for dispute resolution attempts

Regulatory Agencies: You may also contact the following US federal agencies if you believe your rights have been violated:

• Consumer Financial Protection Bureau (CFPB): consumerfinance.gov | 1-855-411-2372
• Federal Trade Commission (FTC): ftc.gov/complaint | 1-877-382-4357
• California Attorney General: oag.ca.gov/privacy