Certain State Privacy Laws Notice

Scope of This State Privacy Notice

This State Privacy Notice applies only to personal information that is not governed by the GLBA, the Fair Credit Reporting Act (FCRA), or other federal laws that exempt such data from state privacy laws. This notice does not apply to residents of states not covered by the applicable state privacy laws, and does not apply to commercial or business users unless required by law.

As a financial services company, most personal information we collect in connection with providing financial products and services is subject to GLBA and exempt from state privacy laws. However, certain information -- such as marketing website data, app usage data, or employment-related data -- may be subject to state privacy laws and is covered by this Notice.

Categories of Personal Information Covered

For purposes of this State Privacy Notice, "personal information" may include:

• Identifiers (e.g., name, email address, IP address)
• Internet or network activity information
• Device and application usage data
• Marketing and advertising data
• Employment or applicant information (if applicable)

This does not include:

• GLBA- or FCRA-covered customer information
• De-identified or aggregated information
• Publicly available information as defined by applicable law

Purposes for Collecting and Using Personal Information

We may collect and use covered personal information for purposes including:

• Operating, maintaining, and improving our websites and applications
• Communicating with consumers and responding to inquiries
• Marketing and advertising (subject to applicable opt-out rights)
• Security, fraud prevention, and risk management
• Legal, regulatory, and compliance purposes

Disclosure of Personal Information

We may disclose personal information to:

• Service providers and processors acting on our behalf
• Affiliates, consistent with applicable law
• Advertising and analytics partners (subject to opt-out rights)
• Government authorities or regulators, as required or permitted by law

We do not sell personal information for monetary consideration. However, certain disclosures for targeted advertising may be considered "sharing" under some state laws.

Consumer Privacy Rights by State

Depending on your state of residence and subject to certain exceptions, you may have the right to:

• Access / Right to Know -- request information about personal data we collect and use
• Correction -- request correction of inaccurate personal information
• Deletion -- request deletion of personal information
• Opt-Out -- opt out of targeted advertising, sale, or sharing (as defined by law)
• Data Portability -- receive a copy of certain personal information
• Non-Discrimination -- not be discriminated against for exercising your rights

These rights apply only to personal information subject to state privacy laws and do not apply to GLBA- or FCRA-covered data.

California-Specific Disclosures

Applicability of the California Consumer Privacy Act (CCPA / CPRA)

The California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), provides certain privacy rights to California residents about whom Occupi has collected personal information. The CCPA applies to businesses that collect and process personal information of California residents, regardless of whether the business is physically located in California.

For purposes of this section, "personal information" means 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 consumer or household.

Occupi has developed and implemented privacy and information security controls designed to protect personal information and comply with applicable U.S. federal laws, including but not limited to the Gramm-Leach-Bliley Act ("GLBA"), Regulation P, and the Fair Credit Reporting Act ("FCRA").

Accordingly, most personal information that Occupi collects, uses, and discloses in connection with providing financial products and services is governed by our Consumer Privacy Notice and is exempt from the CCPA/CPRA. This California-specific section applies only to personal information that is not subject to those federal laws.

California Privacy Rights

Subject to certain limitations and exceptions, California residents have the following rights under the CCPA/CPRA with respect to personal information covered by this State Privacy Notice:

Right to Know / Access

You have the right to request that we disclose:

• The specific pieces of personal information we have collected about you
• The categories of personal information we have collected about you
• The categories of sources from which your personal information was collected
• The business or commercial purposes for collecting or sharing your personal information
• The categories of third parties with whom we share personal information

Right to Delete

You have the right to request the deletion of personal information collected or maintained by us, subject to applicable legal exceptions.

Right to Opt-Out of Sale or Sharing

You have the right to opt out of the sale or sharing of your personal information, as those terms are defined under California law. Occupi does not sell personal information for monetary consideration.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising any of your rights under the CCPA/CPRA.

Occupi:

• Does not sell personal information
• Does not knowingly share personal information of minors under 18
• Does not use or disclose sensitive personal information except as permitted by law

Occupi limits its use of sensitive personal information to purposes permitted by the CCPA/CPRA and applicable regulations.

Important Limitations and Exemptions

Please note that certain personal information we collect, process, or disclose is governed by the GLBA and Regulation P and is therefore exempt from the CCPA/CPRA. For personal information that is not covered by those federal laws, your rights under the CCPA/CPRA apply as described above.

In some instances, we may not be able to honor a request, including where:

• We are unable to verify your identity or authority to make the request
• The request is subject to a legal exemption
• Disclosure would adversely affect the rights and freedoms of another individual
• The personal information is not subject to the CCPA/CPRA

If we are unable to honor your request, we will explain the reason in our response.

In addition, if you request access to specific pieces of personal information, we will not disclose certain sensitive data, including but not limited to:

• Social Security numbers
• Driver's license or government-issued identification numbers
• Financial account numbers
• Account passwords or security credentials
• Security questions and answers

where disclosure would create a risk of identity theft, fraud, or unreasonable risk to data, systems, or network security.

Exercising Your State Privacy Rights

You may submit a privacy rights request by emailing help@occupi.app.

We will verify your identity before responding to your request. In some cases, we may deny a request where permitted by law (e.g., inability to verify identity, legal exemptions, security concerns).

Authorized agents may submit requests on behalf of consumers, subject to verification requirements.

Appeals (Where Required)

Residents of certain states may have the right to appeal our decision regarding a privacy request. If applicable, instructions for submitting an appeal will be included in our response.

Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Notice, comply with legal obligations, resolve disputes, and enforce agreements.

Updates to This State Privacy Notice

We may update this State Privacy Notice from time to time. The effective date at the top of this Notice reflects the most recent revision. If required by law, we will provide notice of material changes to this State Privacy Notice, which may include updating this webpage, sending an email, or providing notice through other appropriate means. We encourage you to review this Notice periodically to stay informed about how we protect your personal information.

Contact Information

If you have questions about this State Privacy Notice or our privacy practices, please contact:

Occupi, Inc.
100 41st Street South
Birmingham, AL 35222
help@occupi.app