Welcome to Justice Bridge Capital. The website www.justicebridgecapital.com (the “Website”) and any related content, products, and services (the “Services”) are provided by Momentum Funding, LLC d/b/a Justice Bridge Capital and its affiliates, representatives, agents, and servicers (“Justice Bridge Capital”, “we,”** “our,” or “us”). We respect your privacy and have designed the Services with your privacy in mind.

This California Consumer Privacy Act Privacy Policy (“Privacy Policy”) explains how Justice Bridge Capital collects, uses, and discloses personal information relating to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”). This Privacy Policy is provided pursuant to the CCPA.

Wherever used in this Privacy Policy, “you” and “your” mean the person or legal entity using the Services. If you are using the Services on behalf of a company (such as your employer) or other legal entity, you represent and warrant that you have the authority to bind that company or other legal entity to this Privacy Policy.

NON-CALIFORNIA RESIDENTS: If you are not a resident of the State of California, please see the general Privacy Policy which applies to non-California residents.

We may update or amend this Privacy Policy in our sole discretion. If we make material changes to this Privacy Policy, we will notify you by posting an updated version on this Website, and will notify active customers in writing. If you object to any changes, you should discontinue the use of the Services. Continued use of the Services after any such changes to the Privacy Policy have been made shall constitute your consent to such changes.

Introduction

Under the CCPA, “Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked directly or indirectly with a particular California resident or household. The CCPA, however, does not apply to certain information, such as information collected, used, or disclosed pursuant to the Gramm-Leach-Bliley Act (“GLBA”) or the federal Fair Credit Reporting Act (“FCRA”).

The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with that individual. For example, this Privacy Policy does not apply with respect to information that we collect about our customers who are California residents and who apply for or obtain our financial products and services for personal, family, or household purposes. For more information about how we collect, disclose, and secure information relating to these customers, please refer to our Privacy Policy.

Keeping Personal Information secure is one of our most important priorities. Consistent with our obligations under applicable laws and regulations, we maintain physical, technical, electronic, procedural, and organizational safeguards and security measures that are designed to protect Personal Information against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access, whether it is processed by us or elsewhere.

Collection of Personal Information

In the past 12 months, we have collected the following categories of Personal Information relating to California residents covered by this Privacy Policy:

• Category A: Identifiers, such as name and government-issued identifier (e.g., Social Security number);
• Category B: Personal information, as defined in the California safeguards law (Cal. Civ. Code § 1798.80(e)), such as contact information and financial information;
• Category C: Characteristics of protected classifications under California or federal law, such as sex;
• Category D: Commercial information, such as transaction information and purchase history;
• Category F: Internet or network activity information, such as browsing history and interactions with our website;
• Category G: Geolocation data, such as device location and Internet Protocol (IP) location;
• Category H: Audio, electronic, visual and similar information, such as call recordings;
• Category K: Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics; and
• Category L: Sensitive personal information, as defined by the CCPA.

Sources from which Personal Information is Collected

The categories of sources from whom we have collected and may collect this Personal Information are:

• Directly from a California resident or the individual’s representatives;
• Service providers and other third parties;
• Public record sources (federal, state, or local government sources);
• Information from our affiliates; and
• Website activity.

Third Parties with whom Personal Information is Disclosed

The categories of third parties to whom we have disclosed and may disclose Personal Information for our business purposes and the categories of Personal Information shared with such third parties are:

• Vendors and service providers who provide technology-related services, such as data storage, digital communications, website hosting, back office programs, data security and audit, and other information technology and related infrastructure (Personal Information Categories A through L listed above);
• Third parties who facilitate providing products and services to our customers, such as transaction and payment processors, financial institutions, call centers, customer and account management systems, collections service providers, data analysis service providers and marketing communications service providers (Personal Information Categories A through L listed above);
• Professional services providers, such as tax and accounting professionals, legal professionals, auditors, marketing professionals and other consultants (Personal Information Categories A, B, and K listed above);
• Other third parties who enable customers to conduct transactions online and via mobile devices (Personal Information Categories B, D, and K listed above); and
• Courts and government agencies (Personal Information Category D listed above).

Use of Personal Information

In the past 12 months, we have used Personal Information relating to California residents to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including the following:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing marketing services, or providing similar services;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Short-term, transient use, where the information is not disclosed to a third party and is not used to build a profile or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
• Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions and auditing compliance with this specification and other standards;
• Undertaking activities to verify or maintain the quality or safety of a service controlled by us and to improve, upgrade, or enhance the service controlled by the business;
• Debugging to identify and repair errors that impair existing intended functionality;
• Undertaking internal research for technological development and demonstration; and
• Complying with laws and regulations and complying with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes, or opinions).

Sale or Sharing of Personal Information

In the past 12 months, we have not sold Personal Information that is subject to the CCPA, including Personal Information of minors under the age of 16, and we will not sell Personal Information except as described in this Privacy Policy or if we provide you with notice and a right to opt-out of such sale. For purposes of this Privacy Policy, “sold” means the disclosure of Personal Information to a third-party for monetary or other valuable consideration.

Do Not Sell or Share My Personal Information. You have the right to direct us to stop sharing your personal information. You may exercise your right to stop us from sharing your personal information by clicking the “Do Not Sell or Share My Personal Information” link here: [insert link to Do Not Sell or Share My Personal Information” page]. “Share” means the sharing or disclosure of Personal Information to a third-party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

Rights under the CCPA

Right to Request Access. You have the right to request that we disclose your Personal Information that we collect, use, and/or disclose to third parties. If you make an access request, you will receive the following information about you:

• Categories of Personal Information collected;
• Categories of sources from which Personal Information are collected;
• Specific pieces of Personal Information collected about you;
• Business or commercial purpose for collecting or selling Personal Information;
• Categories of third parties with whom we share Personal Information; and
• Categories of third parties to whom your Personal Information is sold, if applicable.

This information will be provided free of charge, unless we determine that your request is manifestly unfounded or excessive. You may request this information twice in any 12-month period. This right to request access is subject to certain restrictions and is not available to consumers who have requested information about, applied for, or maintain business credit accounts with us.

Right to Request Deletion. You have the right to request that we and our service providers delete any Personal Information about you that we have collected from you upon receipt of a verifiable request. This right is subject to the same exceptions as for Right to Access requests.

Right to Correct Inaccuracies. You have the right to correct inaccurate personal information that we maintain about you.

Right to Limit Use of Sensitive Information. You have the right to request we limit the use or disclosure of your sensitive personal information to certain legally permitted business reasons. You may exercise your right to limit our use of your sensitive personal information by clicking the “Limit the Use of My Sensitive Personal Information” link here: [insert link to Limit the Use of My Sensitive Personal Information” page].

Right to Non-Discrimination. We will not discriminate against you because you exercised any of your rights, such as by:

• Denying products or services to you;
• Charging different prices or rates for products or services, including through the use of discounts or other benefits or imposing penalties;
• Providing a different level or quality of products or services to you; or
• Suggesting that you will receive a different price or rate for products or services or a different level or quality of products or services.

How to Exercise Your Rights. If you wish to exercise your rights under California law or have questions or concerns, please contact us in one of the following ways:

• Website:  www.justicebridgecapital.com
• Email: team@justicebridgecapital.com
• Phone: 888-533-3515

We will acknowledge receipt of your request within 10 business days and advise you how long we expect it will take to respond if we are able to verify your identity. We will work to process all verified requests within 45 calendar days pursuant to the CCPA. If we need an extension for up to an additional 45 calendar days in order to process your request, we will provide you with an explanation for the delay.

Verifying Access or Deletion Requests. To verify a California Consumer’s identity, we may request up to three pieces of personal information about you when you make a request to compare against our records. We cannot respond to your request or provide you with personal information if we cannot verify your identity. This process is for your protection.

An authorized agent may submit a request on your behalf, in which case we may require proof of your authorization and verification of their identity directly from you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information that you provide in your request to verify your identity. We reserve the right to take additional steps as necessary to verify your identity if we have reason to believe a request is fraudulent.

If we are not able to honor your request, we will let you know the reasons why in our response. Situations where we may not be able to honor your request include:

• If we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual;
• If an exception to the access or deletion right under the CCPA applies, such as when the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer, or when the requested Personal Information is not subject to the CCPA’s access or deletion rights; and
• If your request involves disclosure of social security numbers, driver’s license numbers or government issued identification numbers, financial account numbers, health care or medical identification numbers, account passwords or security questions and answers, or any specific pieces of information, and the requested disclosure presents the possibility of unauthorized access that could result in identity theft or fraud or unreasonable risk to data or systems and network security.

Opt-Out Preference Signals. An “opt-out preference signal” is a signal that is sent by a platform, technology or mechanism, on behalf of the consumer, that communicates the consumer’s choice to opt-out of the sale and sharing of personal information.

We will process any opt-out preference signal that meets both the following legal requirements as a valid request to opt-out of sale or sharing:

• The signal is in a format commonly used and recognized by businesses, for example an HTTP header field or JavaScript object.
• The platform, technology, or mechanism that sends the opt-out preference signal makes clear to you, whether in its configuration or in disclosures to the public, that the use of the signal is meant to have the effect of opting the consumer out of the sale and sharing of their personal information. The configuration or disclosure does not need to be tailored only to California or to refer to California.

If you use an opt-out preference signal that meets the requirements above, we will treat that signal as a valid request to opt-out of sale or sharing of personal information for that browser or device and any consumer profile associated with that browser or device, including pseudonymous profiles. If we know who you are, we will also treat the opt-out preference signal as a valid request to opt-out of sale or sharing for you. If your opt-out preference signal conflicts with privacy setting set with us that allows us to sell or share your personal information (for example, if you have an account with us or use our products or services) we may notify you of the conflict and provide you an opportunity to consent to the sale or sharing of their personal information.

Questions or Concerns

You may contact us with questions or concerns about this Privacy Policy and our practices by calling us at toll free at 1-888-533-3515 or contacting us online at www.justicebridgecapital.com.