Caine & Weiner Company, Inc.
April 1, 2021

General
Caine & Weiner Company, Inc. (“Caine & Weiner Company,” “Caine & Weiner,” “we,” “us” or “our”) respects the privacy of users of our website located at www.connectcw.com (the “Website”). The following Caine & Weiner privacy policy (“Privacy Policy”) is designed to inform you, as a user of the Website, about the types of information that we may gather about or collect from you in connection with your use of the Website. It also is intended to explain the conditions under which Caine & Weiner uses and discloses that information, and your rights in relation to that information. Changes to this Privacy Policy are discussed at the end of this document. Each time you use the Website, however, the current version of this Privacy Policy will apply. Accordingly, each time you use the Website you should check the date of this Privacy Policy (which appears at the beginning of this document) and review any changes since the last time you used the Website.

The Website is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing our Website from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, and by using our Website you consent to that transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of the Website and your agreements with us. Any persons accessing our Website from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use and disclosure, different from those of the jurisdictions mentioned above may only use the Website in a manner lawful in their jurisdiction. If your use of the Website would be unlawful in your jurisdiction, please do not use the Website.

BY USING OR ACCESSING THE WEBSITE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.
GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION

Users of the Website Generally
“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, Caine & Weiner Company gathers from users of the Website Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the websites the user views right before arriving at, while navigating and immediately after leaving the Website. Although such information is not Personally-Identifying Information, it may be possible for Caine & Weiner Company to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. Caine & Weiner Company analyzes Non-Personally-Identifying Information gathered from users of the Website to help Caine & Weiner Company better understand how the Website is being used. By identifying patterns and trends in usage, Caine & Weiner Company is able to better design the Website to improve users’ experiences, both in terms of content and ease of use.

Web Cookies
A “Web Cookie” is a string of information which assigns you a unique identification that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the website. We may use cookies on the Website to keep track of services you have used, to record registration information regarding your login name and password, to record your user preferences, to keep you logged into the Website and to facilitate purchase procedures. Caine & Weiner Company also may use Web Cookies to track the pages that users visit during each Website session, both to help Caine & Weiner improve users’ experiences and to help Caine & Weiner understand how the Website is being used. As with other Non-Personally-Identifying Information gathered from users of the Website, Caine & Weiner analyzes and discloses in aggregated form information gathered using Web Cookies, to help Caine & Weiner, its partners and others better understand how the Website is being used.

CAINE & WEINER USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.

Web Beacons
A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. Caine & Weiner may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information. They are a technique Caine & Weiner may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered, permitting you to accept or decline Web Cookies on an individual basis.

Analytics
We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and serve information based on your past activity on the Website. The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/).

Aggregated and Non-Personally-Identifying Information
We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, for the purpose of conducting general business analysis. This information does not contain any Personally-Identifying Information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.

COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION

Website Registration
As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. Caine & Weiner may collect a range of Personally-Identifying Information from and about Website users. Much of the Personally-Identifying Information collected by Caine & Weiner about users is information provided by users themselves when (1) registering for our service, (2) participating in polls, surveys or other features of our service, or (3) communicating with us, (4) creating a professional profile or (5) signing up to receive newsletters. That information may include each user’s name, address, email address and telephone number. We also may request information about your interests and activities, your gender, age, date of birth, username, address and other demographic or relevant information as determined by Caine & Weiner from time to time. Users of the Website are under no obligation to provide Caine & Weiner with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features.
BY REGISTERING WITH OR USING THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.

Communications
We may occasionally use your name and email address to send you notifications regarding information or services offered by the Company that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt out of such emails at the time of registration or through your account settings, though we reserve the right to send you notices about your account, such as service announcements and administrative messages, even if you opt out of all voluntary email notifications.

Disclosures
Caine & Weiner will disclose Personally-Identifying Information under the following circumstances:

  • By Law or to Protect Rights. When we believe disclosure is appropriate, we may disclose Personally-Identifying Information in connection with efforts to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Caine & Weiner, our users, our employees or others; to comply with applicable law or cooperate with law enforcement; to enforce our Terms of Use or other agreements or policies, in response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
  • Marketing Communications. Unless users opt-out from receiving Caine & Weiner marketing materials upon registration, Caine & Weiner may email users about services that Caine & Weiner believes may be of interest to them. If you wish to opt-out of receiving marketing materials from Caine & Weiner, you may do so by following the unsubscribe link in the email communications, by going to your account settings (if applicable) or contacting us using the contact information below.
  • Third-Party Service Providers. We may share your Personally-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service, performing business analysis, supporting the Website’s functionality and other features offered through the Website. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.
  • Business Transfers. Caine & Weiner reserves the right to transfer all Personally-Identifying Information in its possession to a successor organization in the event of a merger, acquisition or other sale of all or a portion of Caine & Weiner’s assets. Other than to the extent ordered by a court, the use and disclosure of all transferred Personally-Identifying Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and are given an opportunity to affirmatively opt-out of it. Personally-Identifying Information submitted or collected after a transfer may be subject to a new privacy policy adopted by the successor organization.

Changing Personally-Identifying Information; Account Termination
You may at any time review or change your Personally-Identifying Information by going to your account settings (if applicable) or contacting us using the contact information below. Upon your request, we will deactivate or delete your account and contact information from our active databases. Such information will be deactivated or deleted as soon as practicable based on your account activity and accordance with our deactivation policy and applicable law. To make this request, either go to your account settings (if applicable) or contact us as provided below. We will retain in our files some Personally-Identifying Information to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce our Terms of Use and to comply with legal requirements as is permitted by law. Therefore, you should not expect that all your Personally-Identifying Information will be completely removed from our databases in response to your requests. Additionally, we keep a history of changed information to investigate suspected fraud with your account.

General Use
Caine & Weiner uses the Personally-Identifying Information in the file we maintain about you, and other information we obtain from your current and past activities on the Website (1) to deliver the services that you have requested; (2) to manage your account and provide you with customer support; (3) to communicate with you by email, postal mail, telephone and/or mobile devices about services that may be of interest to you from us; (4) to develop and display content tailored to your interests on the Website; (5) to resolve disputes and troubleshoot problems; (6) to measure interest in our services; (7) to inform you of updates; (8) to customize your experience; (9) to detect and protect us against error, fraud and other criminal activity; (10) to enforce our Terms of Use; and (11) to do as otherwise described to you at the time of collection. At times, we may look across multiple users to identify problems. In particular, we may examine your Personally-Identifying Information to identify users using multiple user IDs or aliases. We may compare and review your Personally-Identifying Information for accuracy and to detect errors and omissions.

COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY
Caine & Weiner contractually prohibits its contractors, affiliates, vendors and suppliers from disclosing Personally-Identifying Information received from Caine & Weiner, other than in accordance with this Privacy Policy. Before visiting a third party, or using a third-party application, whether by means of a link on the Website, directly through the Website or otherwise, and before providing any Personally-Identifying Information to any such third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for that website or application, and should take those steps necessary to, in those users’ discretion, protect their privacy.

SECURITY
We take the security of your Personally-Identifying Information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse. However, even the best security measures cannot fully eliminate all risks. We are not responsible for third-party circumvention of any privacy settings or security measures. We are dedicated to protect all information on the Website as is necessary. However, you are responsible for maintaining the confidentiality of your Personally-Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.

PRIVACY POLICY CHANGES
Caine & Weiner may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to Caine & Weiner’s Privacy Policy will be reflected on this page and the date new versions are posted will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. Users should regularly check this page for any changes to this Privacy Policy. Caine & Weiner will always post new versions of the Privacy Policy on the Website. Caine & Weiner may, in its discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users maintain and update their contact information.

CHILDREN
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain Personally-Identifying Information from anyone under the age of 13. Any person who provides Personally-Identifying Information through the Website represents to us that he or she is 13 years of age or older. If we learn that Personally-Identifying Information has been collected from a user under 13 years of age on or through the Website, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has transferred Personally-Identifying Information to the Website, please contact Caine & Weiner using our contact information below to have that child’s account terminated and information deleted.

CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us, once a year and free of charge, information about the Personally-Identifying Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include the Personally-Identifying Information that was shared and the names and addresses of all third parties with which we shared Personally-Identifying Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.

DO-NOT-TRACK POLICY
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. The Website does currently respond to DNT browser signals or mechanisms.

CALIFORNIA CONSUMER PRIVACY ACT
This Privacy Notice for California Residents supplements and is expressly made part of the information contained herein , and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). Caine & Weiner adopts this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

  1. Information We Collect About You
    We may collect and use personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be directly or indirectly linked, with a consumer, device, or household (“personal information”).

Personal Information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, such as (but not limited to) information governed by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the California Confidentiality of Medical Information Act (“CMIA”), the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”), California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994 (“DPPA”).

We regularly collect (and have collected in the past 12 months) several types of personal information about individuals offline regarding accounts we service, including: name, DOB, address, account number, payment and other financial information, email address, insurance information, SSN, employment information, telephone number, IP address, military or veteran status, audio information, usernames, information pertaining to products or services related to obligations owed, records of personal or real property, consuming histories or tendencies, information on any user’s interaction with this site or any site affiliated with H&H, publicly available information, and information collected or shared pursuant to HIPAA, FIPA, GLBA, FCRA, DPPA, and/or other applicable privacy laws. We also may collect additional categories of personal information users provide directly to us or our service providers.

  1. How Your Personal Information is Collected
    We collect most of this personal information from our creditor clients or from you or your authorized representative by telephone or written communications. However, we may also collect information:
  • From publicly accessible sources (e.g., property or other government records);
  • From our service providers (e.g., call analytics, information source, skip-tracing, payment processing, mailing, and other vendors)
  1. Why We Use or Disclose Your Personal Information
    We regularly use or disclose personal information for one or more of the following business purposes:
  • Fulfill the reason you provided the information. For example, if you share your personal information to make a payment, we will use that information to process your payment.
  • Perform services on behalf of a business or service provider, including maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, processing payments, providing analytic services, or providing similar services on behalf of the business or service provider
  • Provide you with information or services that you request from us
  • Auditing related to consumer interactions
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
  • Debugging to identify and repair errors that impair existing intended functionality
  • Short-term, transient use, where the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction
  • Undertaking activities to verify or maintain the quality of a service or device that is owned, made by or for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, made by or for, or controlled by us
  • Respond to law enforcement requests and as required by applicable law or court order
  • As appropriate to protect the rights, property, or safety of us, our clients, or others
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different purposes without providing you notice.

We regularly disclose (and have disclosed in the past 12 months) several types of personal information about individuals for one or more business purposes, including: name, DOB, address, , account number, previous payment and other financial information, email address, insurance information, SSN, employment information, telephone number, IP address, military or veteran status, audio information, usernames, information pertaining to products or services related to obligations owed, records of personal or real property, consuming histories or tendencies, information on any user’s interaction with this site or any site affiliated with H&H, publicly available information, and information collected or shared pursuant to HIPAA, FIPA, GLBA, FCRA, DPPA, and/or other applicable privacy laws

We have not sold your personal information over the last 12 months and will not sell your personal information under the CCPA.

  1. Verifiable Consumer Requests for Information
    Upon verification of identity, California residents may in some cases request that a business:
  • Disclose the categories of personal information the business collected about the consumer;
  • Disclose the categories of sources from which the personal information is collected
  • Disclose the categories of personal information that the business sold about the consumer;
  • Disclose the categories of personal information that the business disclosed about the consumer for a business purpose;
  • Disclose the categories of third parties with whom the business shares personal information
  • Disclose specific pieces of personal information the business has collected about the consumer
  • Disclose any financial incentives offered by the business for collection, sale, or deletion of personal information

Please note that we are not required to:

  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
  • Re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information;
  • Provide the requested information disclosure to you more than twice in a 12-month period.
  • Provide the requested information disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf; or
  • Provide the requested information disclosure if a CCPA or applicable exception applies.

We may deny your request if we are acting in the role of a service provider to another business regarding the applicable personal information. If we deny your request on that basis, we will generally refer you to the relevant business to obtain the requested information.

  1. Right to Request Deletion of Personal Information
    Upon verification of identity, California residents may in some cases request that we delete personal information about you that we collected from you and retained, subject to certain exceptions.

    We may deny your deletion request if we are acting in the role of a service provider to another business regarding the applicable personal information. If we deny your request on that basis, we will generally refer you to the relevant business. In addition, we may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
  • Debug to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act.
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent.
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information; or
  • If another CCPA or applicable exception applies.
  1. Verifying Your Identity If You Submit CCPA Requests
    If you choose to contact us directly via the designated methods described above to exercise your CCPA rights, you will need to:
  • 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 are not obligated to make an information disclosure or carry out a deletion request pursuant to the CCPA if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

    Any personal information we collect from you in order to verify your identity in connection with your CCPA request will be used solely for the purposes of verification.

  1. Response Timing and Format
    We endeavor to respond to a verifiable consumer request within forty-five (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.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.We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
  1. Contacting Us and Exercising Your Rights
    If you have any questions or comments about this notice, the ways in which Caine & Weiner collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:Phone: 818-226-6000
    Email: [email protected]
    Mail: 5805 Sepulveda Blvd., 4th Floor, Sherman Oaks, CA 91411
  1. Changes to this Policy
    Caine & Weiner reserves the right to modify and amend this Policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated Notice on the website and update the effective date.

CONTACT
If you have any questions regarding our Privacy Policy, please contact our Privacy Officer at:
Caine & Weiner Company, Inc.
Attn: Privacy Officer
5805 Sepulveda Blvd. 4th Floor Sherman Oaks, CA 91411
Email: [email protected]
Phone: (818) 226-6000