Geneva Capital Privacy Policy

Last Updated: September 16, 2025

This Privacy Policy (the “Policy”) describes the types of personal information Geneva Capital collects about you through its operation of its business, how we use that information, who we disclose it to, and certain rights and options you may have regarding your personal information.

This Policy applies to information we collect from you through our website or other digital properties, as well as when you communicate with us, interact with us, or otherwise provide us with personal information. You may be presented with other privacy notices during the course of interacting with us or using our services; this Policy supplements those other notices.

By using one of our website or digital properties, communicating with us, or otherwise interacting with us, you consent and agree to our collection, use, and disclosure of your personal information as described in this Policy.

We may update this Policy from time to time, including to add disclosures that may be required by newly applicable or changing laws. Please check back often for updates.

Personal Information We Collect or Receive About You

A. Personal Information

For the purposes of this Policy, “personal information” is any information that, either alone or in combination with other information, identifies, relates to, or can be used to contact a particular individual. Because we service business customers, the personal information we process is often the types of information found on a business card or collected in similar commercial capacities. The types of personal information we may collect include the following categories.

Contact information: First name, last name, email address, mailing address, telephone number, your employer and position.
Account details: If you create or register an account with us, your username, password, account number, and other account details that are requested as part of the account setup and management process (e.g., your preferences or areas of interest).
Business information: If you are a prospective or existing operational partner, customer, or business contact, details of the services or financial products you or your organization is interested in, you or your organization’s business needs, or other information you provide in connection with an inquiry or communication regarding our services.
Transactional data: Details about your transactions with us, including method of payment, relevant billing addresses, payments received, transaction history, and other information relating to the financial products or services purchased by you.
Application information: If you apply for a financial product, the details of the equipment you intend to finance (including supplier, description, or location), the details of your business (including ownership or securities held), your social security number, tax ID number, government ID information, the details of your citizenship or immigration status, spousal information (to the extent relevant to a credit decision), copies of bank statements, banking account information, and other details that are requested at the time of or in connection with your application.
Marketing information: Details regarding promotional materials you may have requested or received from us, the services in which you are interested, your receipt of newsletters or other promotional communications, and information on your marketing or communication preferences.
Geolocation information: In some cases, we may collect information from your browser or device that identifies the location of that device. Oftentimes, you will be prompted by the browser or device manufacturer to consent to our collection of this information. This assists us with ensuring that our website and digital properties are tailored to your geographic location.
Customer communications: Copies of communications or inquiries you have submitted to us, including through email, calls, chat functionalities on our website or digital properties, forms, social media, or other means. This includes information you provide in response to customer surveys, quizzes, questionnaires, or intake forms.
Device, usage, and preference information: Details regarding how and when you use our website, including the device used to connect to the website, your IP address and device identifier, the frequency and duration of your usage, the pages you view, what websites or search terms referred you to the website, and information about your interaction with the website. We also collect information regarding the content viewed and issues queried while on our website or any other digital properties (e.g., articles read or saved, pages visited, information searched for, etc.).

We collect this information when you access, use, or navigate one of our website or other digital properties, create an account with us or use an existing account to engage with one of our website or other digital properties, fill in forms via one of our website or other digital properties, request information from us, communicate with us (including by phone, email, chat, or otherwise), interact with any chatbot or similar features available via one of our website or other digital properties, visit or engage with our social media pages, participate in surveys or sponsored activities, or otherwise provide us with personal information.

If you do not provide us with certain information, then the digital property you are using may not function as intended, or you may not be able to benefit or take advantage of certain features of our products or services. For example, if you do not provide us with your name and email address, you cannot create an account with us.

Where we have an ongoing relationship with you, and any of the data you have provided (e.g., your contact information) is no longer accurate, please inform us of this so we can amend our records accordingly.

Please note that we may aggregate or anonymize the foregoing types of information such that they are no longer capable of identifying you, in which case they are no longer considered “personal information.”

B. Automatically Collected Information

Like most digital property operators, we use various technologies to collect certain types of information about the users of our digital properties. Note, the vendors that supply us pixels, tags, web beacons, cookies, and the other tracking technologies discussed below collect your personal information instantaneously and simultaneous to our collection of such information. They may also use such personal information for their own or others’ purposes.

The technologies we use on our website and other digital properties include:

Pixels, tags, web beacons, gifs, and similar code-based technologies. These technologies are small pieces of code that run when a website or other digital properties page or email is loaded. They are used to monitor the behavior of the visitor or email recipient—such as what icons were clicked or whether links in an email were opened—and gather analytics and details about the interaction. For example, when you open our homepage, a pixel may run and generate information based on the visit (e.g., your IP address and what day and time you were on the homepage), and then this information is processed by us or our vendors. Pixels work in conjunction with cookies to let us know what portions of our digital properties are of interest to you and to help us provide you with tailored information. Even if you have disabled or turned off cookies (discussed below), the pixels, tags, and web beacons we use may still detect and collect certain information about your interaction with our website or other digital properties; in other words, these kinds of technologies may disregard any cookie-prohibitive markers or signals.
Cookies: Cookies are small text files that can be used by websites to make a user’s experience more efficient. Our website uses different types of cookies to, among other things, automatically recognize you when you return to our site, store information regarding your preferences, and analyze traffic to our site. Please note that where cookies are essential to the operation of our site, if disabled, you may not be able to enjoy certain features of the site. For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org. We do not honor “Do Not Track” signals. Continue reading below to learn more about the Global Privacy Control.
Log Files and Device Identifiers. We use log files to track actions occurring on digital properties and to collect data about visitors, including IP address, browser type, Internet service provider, referring/exit pages, date/time stamps, and device identifiers.
Analytics. Our digital properties may also deploy third-party analytics tools, such as Google Analytics. You can find more information about how data is collected and processed in connection with the Google Analytics service at https://policies.google.com/technologies/partner-sites. You can also read Google’s privacy policy at https://policies.google.com/privacy?hl=en.

The information collected through these technologies may be combined with personal information or aggregated with other information on website visits. We may share information about your use of our website with our advertising and analytics partners, who may combine it with other information that you previously provided to them.

Please see the Section titled “Your Choices About Your Personal Information” for more information about options you may have to configure pixels, tags, cookies, and similar technologies on our website or other digital properties.

C. Information from Other Sources

We may obtain both personal and non-personal information about you from other users of our website and services, business partners, suppliers, and other third parties and add it to other information we have collected. For example, as mentioned above, Geneva Capital makes your personal information available to the vendors that assist us with conducting background and credit checks. Thus, we may receive personal information about you from these types of sources.

We, and the third parties we engage, may combine information we collect from you over time and across your online activity with information obtained from other sources. For example, we may purchase consumer data from a data broker and use that information to supplement the information we have collected about your activities directly. This helps us improve the information’s overall accuracy and completeness and also helps us better tailor our interactions with you.

D. Social Media

If you interact with us on any social media platform: (i) depending on your social media privacy settings, the personal information that you submit on the social media platform may be read, collected, or used by us as described in this Policy, and (ii) where we respond to any interaction with you on social media, your account name/handle may be viewable by any and all members or users of our social media accounts. Social media platforms operate independently from us and we are not responsible for the personal information that you choose to submit or link on any social media platform. We encourage you to review the privacy policies and settings of any social media platform with which you interact to help you understand their privacy practices.

How We Use Your Personal Information

We (or service providers acting on our behalf) may use the personal information identified above for the following purposes:

Processing applications for and entering into agreements for our financial products or services, and fulfilling the delivery of such products or services to you.
Authenticating your credentials or facilitating any login to our systems or services, including through the use of single-sign-on options provided by third parties.
Managing our relationship with you or your business, including entering into and fulfilling any transactions with you or your business.
Facilitating and displaying advertisements from third parties on our website or other digital properties, including, in some cases, ensuring the ad is relevant to your interests.
Engaging in targeted advertising on other websites or mobile applications, even if those websites or mobile applications are owned by third parties.
Enabling our vendors and commercial partners to advertise their products or services to you.
Operating our business, including engaging in accounting, auditing, invoicing, or reconciliation and collection activities, determining the effectiveness of our marketing or sales strategies or processes, managing our communications.
Analyzing market and consumer trends and developing financial, product, or profile insights.
Enhancing your experience on our digital properties, including by identifying and displaying content that might be of interest to you and otherwise ensuring that our content is presented to you in a useful and effective manner.
Communicating with you and responding to your inquiries and communicating regarding our services, the functionality of our digital properties, and other issues.
Sending you informational communications and promotional solicitations, tracking your marketing preferences, and for our internal marketing purposes.
Managing customer service issues, including issues relating to the performance of our services and customer feedback.
Developing, updating, and improving our products and services, our administrative processes that support our business, and customer experience, and otherwise improving our knowledge and insights regarding customers.
Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the use of our website or other digital properties or use of our products or services.
Enforcing our agreements with you or our organizational partners and customers, complying with our legal or regulatory obligations, and defending or advancing legal claims.
Notifying you about changes to our services or material changes to this Policy.
Providing you with surveys or otherwise soliciting feedback from you.
Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.

For more information about your options relating to your personal information and your communication preferences, see “Your Choices About Your Personal Information” below.

Disclosure of Your Personal Information

When the information we collect about you is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or disclose it to third parties, to the extent permitted by applicable law.

In addition, we may disclose your personal information to the following types of individuals or entities:

Service providers we use to facilitate our business operations and administer our services. These parties have access to your personal information to perform specific tasks on our behalf. For example, our service providers include (i) IT and system administration providers, (ii) data storage and server providers, (iii) web hosting providers, and (iv) vendors to facilitate payments and payment processing.
Individuals or organizations to whom you direct us to provide your information, for example a provider or local resource that you identify through our services and direct us to disclose your contact information to.
Equipment manufacturers or vendors with whom we partner to offer our financial products and services to end customers.
The vendors that assist us with background and credit checks.
Organizations with whom you have a relationship or are affiliated, such as your employer, a relevant equipment manufacturer or supplier, or other commercial party.
Vendors whose technologies we leverage to provide certain features of our website or other digital properties, such as video players and chat software providers.
Marketing and advertising vendors that may assist with lead generation, hosting information relating to customers and business partners and potential customers or business partners, marketing automation, advertisement placement and targeting, and marketing campaigns and communications. Examples of these vendors include Meta and LinkedIn.
Analytics vendors in order to understand our website traffic and usage patterns, optimize our website, track marketing conversions, and identify potential new customers or users.
Our affiliates and related entities, investors, and operational partners.
Our professional advisors, such as lawyers, accountants, and other similar advisors.
Other parties for any purpose we disclose at the time you provide the information.

We may also disclose your personal information to:

Buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred.
Regulatory and governmental authorities, law enforcement agencies, and courts, as necessary to comply with applicable laws and regulations, respond to a subpoena, search warrant, or other lawful request for information, or to otherwise protect our rights.
Protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and risk reduction.
Enforce or apply the terms and conditions of our website or other digital properties, any terms and conditions of purchase (to the extent applicable), and other agreements between you and Geneva Capital.

Note, the technology vendors we use to make our digital properties available to you may collect your personal information instantaneously and simultaneous with us collecting the same information.

Our Marketing Efforts

We may send you direct marketing communications from time to time via physical or electronic mail, including news, updates, and other announcements relating to our services and business activities. We will only send marketing messages where the law allows us to do so and, in the event that you no longer wish to receive marketing communications from us, then you can always unsubscribe from our marketing communications using the functionality in the communication you have received or by contacting us at the information below. Where permitted by applicable laws, we may send you informational or promotional communications via text or SMS message.

Information for Job Applicants or Candidates

If you are a job applicant or candidate for Geneva Capital, we will collect your personal information to evaluate your qualifications, communicate regarding opportunities, and manage recruitment processes. This may include your contact details, resume, employment history, education, references, and any other information you choose to provide. We may also collect data from publicly available sources or third-party recruiters. We may disclose your personal information to our service providers or affiliates involved in recruitment or to whom your application may be of interest. If you are an applicant from outside of the United States, your personal information will be transferred to the United States where we are located. Applicants may request more information about our personal information practices by contacting us.

Your Choices About Your Personal Information

A. Tracking Technologies and Advertising

Depending on your browser or device, you may have the option to set the browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies. Each browser and device are different, so we recommend you evaluate the tools and settings available in your browser or device, as well as any available instructions for the same. Please note that if you disable or delete cookies, you may not be able to access or use certain features of our website.

The National Advertising Initiative also makes resources available to assist consumers in opt-out of certain tailored online ads, which you can access at https://optout.networkadvertising.org/?c=1.

B. Marketing Communications and Emails

You may choose to opt out of marketing emails by using the “Unsubscribe” link found at the bottom of such emails. You can configure your device settings to disable push notifications. You can opt out of receiving promotional communications via text or SMS message by texting “STOP” or “OPT OUT” to the number provided. You can opt out of receiving certain communications by contacting us at the “Contact Us” information below.

C. Google Analytics

As discussed above, we use Google Analytics in connection with the website. If you would like to refrain from having your data collected by Google Analytics, Google has developed an opt-out browser that you can access at https://tools.google.com/dlpage/gaoptout?hl=en-US. You can find more information on how Google uses information it collects at https://policies.google.com/technologies/partner-sites.

D. Updating Your Information

We take reasonable steps to keep your personal information accurate and complete. You can access or update your personal information, including contact or account information, by contacting us at the “Contact Us” information below.

E. Declining to Provide Information

You can choose not to provide us with information we may request, but that may result in you being unable to use certain features of our website or other digital properties, request information about our services, or initiate other transactions with us.

F. Do Not Track Mechanisms

Please note that our websites do not honor “Do Not Track” signals, and such signals will not impact the operation of our websites. Do Not Track signals are different than the Global Privacy Control (more information about GPC can be found at https://globalprivacycontrol.org/).

Additional Information for California Residents

This section of our Policy applies solely to “consumers” as defined by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), and describes our activities when we are acting as a business, as defined by the CCPA.

CALIFORNIA NOTICE AT COLLECTION

In simply accessing one of our website or other digital properties, the following applies. If you create an account or interact with us in other ways (e.g., by filling out forms on our website or other digital properties), please continue reading below to learn more about the personal information we collect, and how we use and disclose such information.

Categories of personal information to be collected

**We do not collect and process any sensitive personal information

· Identifiers, such as your IP address, device ID, browser ID, mobile ad ID, or other unique or personal online or electronic identifier associated with the means by which you access the website or other digital properties

· Internet activity, such as browsing details, search details, information about your interaction with the website, application, or advertisement, including page views, clicking tendencies, and time spent on a page, and other similar event or session data

· Geolocation information, such as the city and state associated with your IP address

· Inferences drawn from the above information to create a profile about you reflecting your preferences or characteristics

The purposes for which the above categories of personal information are collected and used

· Providing and optimizing your experience on our digital properties and ensuring that our content is presented to you in the most effective manner

· Engaging in analytics regarding use of our digital properties by users for the purposes of marketing to current or potential customers.

· Developing, updating, and improving our services, including our digital properties

· To help maintain the safety, security, and integrity of our websites and mobile applications

· Preventing and detecting fraud, hacking activities, security breaches, and other unlawful activities in connection with our website and mobile applications

· Enforcing our agreements and complying with our legal or regulatory obligations

The criteria used by us to determine the period for which the personal information will be retained

Geneva Capital will retain the personal information it collects and uses so long as it has a legitimate business need to do so, or as required by law (e.g., for tax, legal, accounting or other purposes), whichever is the longer.

Geneva Capital “shares” (as that term is defined by the CCPA) the following categories of personal information to various marketing and advertising vendors for the purposes of serving you with targeted advertisements, either on behalf of us or third parties.

Identifiers, such as your IP address, device ID, browser ID, mobile ad ID, or other unique or personal online or electronic identifier associated with the means by which you access the website or other digital properties
Internet activity, such as browsing details, search details, information about your interaction with the website, application, or advertisement, including page views, clicking tendencies, and time spent on a page, and other similar event or session data

To request that Geneva Capital opt you out of the sharing of such information, please use our cookie banner to configure your settings to decline targeted advertising or marketing technologies from functioning.

CALIFORNIA PRIVACY POLICY

To learn more about our practices in connection with the collection, processing, and disclosure of personal information relating to California consumers, continue to read below.

A. Personal Information We Collect and Disclose

As defined by the CCPA, “personal information” includes any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. For the purposes of the CCPA and this section, personal information does not include certain regulated information or public information.

In the past 12 months, Geneva Capital has collected the following categories of personal information from consumers and disclosed such information to the following categories of third parties for the business or commercial purposes described below.

CATEGORIES OF PERSONAL INFORMATION
Categories of PI Collected	Examples	Categories of Third Parties to Whom Disclosed
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, device ID, mobile ad ID, browser ID, email address, account username, or other similar identifiers	· IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers and IT consultants · Analytics and marketing/advertising vendors and service providers · Individuals or organizations to whom you direct us to provide your information, for example an equipment manufacturer · Organizations with whom you have a relationship or are affiliated, such as your employer · Financial institutions and payment processors · Professional advisors (accountants, lawyers, and auditors)
Commercial information	Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	· IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers and IT consultants · Analytics and marketing/advertising vendors and service providers · Individuals or organizations to whom you direct us to provide your information, for example an equipment manufacturer · Organizations with whom you have a relationship or are affiliated, such as your employer · Financial institutions and payment processors · Professional advisors (accountants, lawyers, and auditors)
Internet or other similar network activity	Browsing details, search details, information about your interaction with the website, mobile application, or advertisement, including page views, clicking tendencies, and time spent on a page, and other similar event or session data.	· IT and cloud/hosting service providers · Online analytics and marketing/advertising service providers
Personal information types listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, physical characteristics or description, address, telephone number	· IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers and IT consultants · Analytics and marketing/advertising vendors and service providers · Individuals or organizations to whom you direct us to provide your information, for example an equipment manufacturer · Organizations with whom you have a relationship or are affiliated, such as your employer · Financial institutions and payment processors · Professional advisors (accountants, lawyers, and auditors)
Sensory data	Voicemail or similar audio recordings	· IT and cloud/hosting service providers
Characteristics of protected classifications under California or federal law	Age, race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status, genetic information (including familial genetic information)	· IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers and IT consultants · Credit and background check vendors
Geolocation data	The city and state associated with your IP address (not precise)	· IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers and IT consultants · Analytics and marketing/advertising vendors and service providers
Inferences drawn from other information	Inferences drawn from the above categories of information to create a profile about you reflecting your preferences or characteristics	· IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers and IT consultants · Analytics and marketing/advertising vendors and service providers
SENSITIVE PERSONAL INFORMATION
Information that reveals a consumer’s social security, driver’s license, state identification card, or passport number	Any details you choose to make available as part of application for a financial product or service	· Vendors and service providers, such as IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers and IT consultants
Information that reveals a consumer’s account log-in details	Username and password, together with any security questions and answers	· Vendors and service providers, such as IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers and IT consultants
Information that reveals a consumer’s citizenship or immigration status	Any details you choose to make available as part of application for a financial product or service	· Vendors and service providers, such as IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers and IT consultants

From time to time, Geneva Capital may be required to disclose your information to governmental authorities for the purpose of complying with applicable laws and regulations or in response to legal process. We may also disclose your personal information to third parties in connection with the sale of our business or assets, or any merger or similar corporate matter, when your personal information is part of the assets involved in such transaction.

B. Applicable Retention Periods

For each category of personal information identified above, we will retain your personal information only for as long as necessary to fulfill your requests or the purposes for which it was obtained, as set forth in this section. The criteria used to determine our retention periods include (i) to fulfill the purpose for which the information was collected, (ii) for as long as we have an ongoing relationship with you, and (iii) as required by a legal obligation to which we are subject.

C. Categories of Sources of Personal Information

Geneva Capital collects these categories of personal information from the following categories of sources:

Direct collection: We collect information directly from you when you choose to provide it to us by completing an application for our products or services, creating an account with us, engaging in transactions with us, signing up to receive promotional or information communications from us, communicating with us about our services, or otherwise directly providing the information to us.

Technology-based collection: We also collect certain information from you automatically when you visit, use, or navigate our digital properties. Geneva Capital collects certain identifiers (such as IP addresses, device IDs, mobile ad IDs) and internet and similar network activity (such as website usage data) from you indirectly using cookie, pixels, and passive tracking technologies, as described in the “Automatically Collected Information” section of our Policy above.

Collection via social media: We may collect personal information about social media users, including basic user profile information (such as username), user-generated content (such as posts, comments, pages, profiles, or feeds) and associated metadata (such as time and location of a post or comment); contact details (such as name, email address, telephone number, if made public by the user); and additional individual information published by the user (such as employer, profession, age, location, education information, habits, etc.). The type and scope of personal data obtained from social media platforms depends on the type of APIs and permissions set out by the respective platforms and the administrative permissions granted by customers, where applicable.
Third-party collection: On occasion, we may obtain consumer data from brokers or marketing vendors. We use this personal information to supplement the personal information we collect from you directly for our marketing and advertising purposes. We also receive personal information from consumers’ employers.

D. Business or Commercial Purposes for Collecting and Disclosing Personal Information

We collect and disclose the personal information described above for the following business or commercial purposes:

Processing applications for and entering into agreements for our financial products or services, and fulfilling the delivery of such products or services to you.
Authenticating your credentials or facilitating any login to our systems or services, including through the use of single-sign-on options provided by third parties.
Managing our relationship with you or your business, including entering into and fulfilling any transactions with you or your business.
Facilitating and displaying advertisements from third parties on our website or other digital properties, including, in some cases, ensuring the ad is relevant to your interests.
Engaging in targeted advertising on other websites or mobile applications, even if those websites or mobile applications are owned by third parties.
Enabling our vendors and commercial partners to advertise their products or services to you.
Operating our business, including engaging in accounting, auditing, invoicing, or reconciliation and collection activities, determining the effectiveness of our marketing or sales strategies or processes, managing our communications.
Analyzing market and consumer trends and developing financial, product, or profile insights.
Enhancing your experience on our digital properties, including by identifying and displaying content that might be of interest to you and otherwise ensuring that our content is presented to you in a useful and effective manner.
Communicating with you and responding to your inquiries and communicating regarding our services, the functionality of our digital properties, and other issues.
Sending you informational communications and promotional solicitations, tracking your marketing preferences, and for our internal marketing purposes.
Managing customer service issues, including issues relating to the performance of our services and customer feedback.
Developing, updating, and improving our products and services, our administrative processes that support our business, and customer experience, and otherwise improving our knowledge and insights regarding customers.
Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the use of our website or other digital properties or use of our products or services.
Enforcing our agreements with you or our organizational partners and customers, complying with our legal or regulatory obligations, and defending or advancing legal claims.
Notifying you about changes to our services or material changes to this Policy.
Providing you with surveys or otherwise soliciting feedback from you.
Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.

E. Sensitive Personal Information

As described above, Geneva Capital uses and discloses certain “sensitive personal information” (as defined by the CCPA). In some cases, we use or disclose sensitive personal information to process applications for our products or services. In connection with the foregoing, the information is collected or processed without the purpose of inferring characteristics about you, so we treat the information like “personal information” for CCPA purposes.

F. Sale or Sharing of Personal Information

In the past 12 months, Geneva Capital has “shared” (as that term is defined by the CCPA) the following categories of personal information to various marketing and advertising vendors for the purposes of serving you with targeted advertisements, either on behalf of us or third parties.

Identifiers, such as your IP address, device ID, browser ID, mobile ad ID, or other unique or personal online or electronic identifier associated with the means by which you access the website or other digital properties.
Internet activity, such as browsing details, search details, information about your interaction with the website, application, or advertisement, including page views, clicking tendencies, and time spent on a page, and other similar event or session data.

In the past 12 months, Geneva Capital has “sold” (as that term is defined by the CCPA) individuals’ contact (i.e., name and email address) to commercial partners who use such information as a prospective customer lead for advertising or marketing purposes.

Please review the “Exercising Your Right to Opt-Out of ‘Shares’ and ‘Sales”” section below for instructions on how to opt out of “shares” or “sales.”

Geneva Capital does not have actual knowledge that it sells or shares the personal information of consumers under 16 years of age.

G. Your Rights Under the CCPA

Subject to exceptions, the CCPA provides California residents with the rights discussed below. For convenience, and as required by the CCPA, we explain how you can exercise those rights, to the extent they are applicable.

Right to Know. You have the right to request that we provide you certain information about our collection and use of your personal information during the past twelve (12) months (or longer, as permitted by the CCPA). Specifically, you may request that we disclose (in whole or part):

The categories of personal information we collected about you;
The categories of sources for the personal information we collected about you;
The business and commercial purposes for collecting (or selling or sharing, if applicable) your personal information;
The categories of third parties to whom we disclose (or sell or share, if applicable) your personal information;
The specific pieces of personal information we collected about you;
If we disclosed your personal information for a business purpose, the categories of personal information received by each category of third party; and
If applicable, the categories of personal information that we sold, and for each category, the categories of third parties whom such information was sold.

As noted above, you have the right to request that we provide copies of the specific pieces of personal information we collected about you. If a verifiable consumer request is made, and subject to any exceptions or limitations under the CCPA, we will take steps to deliver the personal information to you either by mail or electronically. If we provide the information to you electronically, it will be in a portable and readily useable format, to the extent technically feasible. Consistent with the CCPA and our interest in the security of your personal information, we will describe but may not provide copies of certain personal information we may receive from you (e.g., driver’s license number, other government-issued identification number, financial account number, account password, or security questions or answers) in response to a CCPA request, to the extent any of those items are in our possession.

Right to Request Deletion. You have the right to request that we delete personal information we collected from you, subject to any exceptions or limitations under the CCPA.
Right to Correct Inaccurate Information. If we maintain inaccurate personal information about you, you have the right to request that we correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
Right to Opt-Out of Sales or Sharing. You have the right to request that we opt you out of the “sharing” of your personal information for the purposes of cross-context behavioral advertising. You also have the right to opt out of “sales” of your personal information.
Right to Limit Use or Disclosure of Sensitive Personal Information. You have the right to direct us to limit our use and disclosure of your sensitive personal information for certain purposes, where the law allows and subject to applicable exceptions or limitations. We do not process sensitive personal information for the purposes of inferring characteristics about you; thus, this right is not available.

H. Exercising Your Right to Know, Request Deletion, or Correct Inaccurate Information

To exercise the rights described above, you—or someone authorized to act on your behalf—must submit a verifiable consumer request to us by sending an e-mail to: info@gogc.com with the subject line: “CCPA Request,” or calling us at 1-800-408-9352. Your request must include your name, email address, mailing address, phone number, the nature of your inquiry and the context in which we may have received your information. If you are an agent submitting a request on behalf of a consumer, we may request that you submit a signed permission from the consumer authorizing you to make the request. In order to protect the privacy and data security of consumers, 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 of such consumer; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

As indicated above, please be aware that the CCPA provides certain limitations and exceptions to the foregoing rights, which may result in us denying or limiting our response to your request.

You may only make a verifiable consumer request to know twice within a 12-month period. 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 may also request that you provide additional information if needed to verify your identity or authority to make the request. 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 or the consumer on whose behalf you are making the request.

The CCPA requires us to respond to a verifiable consumer request within forty-five (45) days of its receipt; however, we may extend that period by an additional 45 days. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response via e-mail. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request, provided that you may request disclosure beyond the 12-month period as permitted by the CCPA. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For requests to know specific pieces of information collected about you, we will select the format of our response; the format will be readily useable and should allow you to transmit the information from one entity to another. We will not charge a fee to process or respond to a 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 the request.

I. Exercising Your Right to Opt-Out of “Shares” or “Sales” of Your Personal Information

For information collected from you through our use of automatic technologies on our website or other digital properties: You can opt out of the sharing of your personal information by configuring our cookie banner accordingly. Your actions only apply to the browser or device you are using to interact with our website or other digital properties and not to other devices or browsers. If you clear your cookies or change your preferences on a particular browser or device, or use another browser or device to interact with our digital properties, you may need to complete the action again.

For contact information “sold” to commercial partners: You can submit a request to opt out the sale of your personal information by emailing us at info@gogc.com with the subject, “Opting Out of Sales.”

The CCPA requires us to comply with the above requests as soon as feasibly possible, but no later than fifteen (15) business days from the date the request is received. No verification is required; however, we may deny a request if we have a good-faith, reasonable, and documented belief that the request is fraudulent. In the event we deny a request for this reason, we will inform the consumer that we are not complying with the request and provide an explanation of why we believe the request is fraudulent.

Requests may be made using an authorized agent, if the consumer provides the agent with written permission signed by the consumer to act on the consumer’s behalf. We may deny a request if the applicable agent does not submit proof that it has been authorized by the consumer to act on the consumer’s behalf.

Once a consumer makes the request, we will honor such request for at least twelve (12) months before asking the consumer to reauthorize certain personal information usage. Additionally, if a consumer initiates a transaction or attempts to use a product or service that requires certain uses of personal information, we may inform the consumer that the transaction, product or service requires the use or disclosure of the consumer’s personal information and provide the consumer instructions on how to opt it or consent.

J. Our Commitment Not to Discriminate

Consistent with the CCPA, we will not discriminate against you for exercising any of your CCPA rights by:

Denying you goods or services.
Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Providing you a different level or quality of goods or services.
Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

K. Data Disclosures for Direct Marketing Purposes

California Civil Code § 1798.83 (California’s Shine the Light Act) further permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from providing your personal information to certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at the contact information below.

Data Retention

We retain personal information for as long as necessary to fulfil the purposes we collected it, including for the purposes of satisfying any legal, accounting, or other mandatory reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, whether we can achieve those purposes through other means, and the applicable legal requirements. We also consider any specific limitation periods under applicable law.

Information Security

We use appropriate administrative, technical, and physical measures to protect your personal information from loss, theft, and unauthorized use, disclosure, or modification. Please be aware that no data transmission over the Internet is 100% secure. While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us and you do so at your own risk.

Links to Third-Party Websites

Our digital properties may contain links to third-party digital properties (e.g., social media sites). Such third-party digital properties have separate privacy policies that you should review. We cannot and do not take responsibility for the content of linked websites or those companies’ data-handling practices.

Privacy of Children Online

Our digital properties are intended for use by a general audience. We do not knowingly collect the personal information of any individual under the age of 13. If you believe we have collected the personal information of a child under 13, please email us at the information provided below.

Changes to the Privacy Policy

While we always aim to provide complete and transparent information about how we process your personal information, we reserve the right to amend or update this Policy from time to time or to create additional policies in order to accurately reflect changed circumstances or new legal requirements.

Please note that we may change this Policy from time to time. If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of the website after any changes is deemed to be acceptance of those changes. Accordingly, we encourage you to check the Policy periodically for updates.

Contact Us

If you have any questions regarding our information handling practices, you may contact us at:

Email: info@gogc.com

Postal Address:
Geneva Capital, LLC
1311 Broadway St.
Alexandria, MN 56308

Phone: 320-762-8400
Toll free: 1-800-408-9352
Fax: 1-320-762-8402