Last updated November 1, 2025

 

Who this notice applies to

Your privacy matters to us. This notice explains how BestCitizenBank (“Company,” “we,” or “us”) collects, uses and discloses personal information about California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (CPRA). We provide this notice as required by the CCPA/CPRA.

 

Overview

Under the CCPA/CPRA, ‘Personal Information’ means information that identifies a particular California resident, relates to them, or could reasonably be linked to them directly or indirectly. Some information sits outside the CCPA/CPRA, including information covered by the Gramm-Leach-Bliley Act (“GLBA”).

The specific Personal Information we collect, use and disclose about a covered California resident depends on the relationship or interaction we have with that person. For instance, this Disclosure does not cover information we collect about California residents who apply for, or receive, our products and services for personal, family, or household purposes. To learn how we collect, disclose and protect information about those customers, please see our Privacy Notice.

Keeping Personal Information safe is one of our most important priorities. As the law and regulations require, we maintain physical, technical, electronic, procedural and organizational safeguards and security measures designed to protect personal data from accidental, unlawful or unauthorized destruction, loss, alteration, disclosure or access, whether we process it or someone else does.

 

What we collect and share

Over the past 12 months, we have collected, and shared with third parties for our business purposes, the following categories of Personal Information about California residents covered by this disclosure:

• Identifiers, such as your name, a government-issued identifier (for example, Social Security number, driver’s license number, passport number), email address, account name, or other similar identifiers;
• Personal information, as defined in the California safeguards law, such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification number, insurance policy number, and information such as account, card, or card numbers.
• Characteristics that California or federal law treats as protected, such as race, color, national origin, citizenship, religion or creed, marital status, disability, sex, or veteran or military status.
• Commercial information, such as records of personal property, details, and buying or consuming histories or tendencies;
• Internet or network activity information, such as browsing history, search history, and details of how you interact with our website or app;
• Geolocation data, such as the location of your device and its Internet Protocol (IP) location;
• Audio, electronic, visual and similar information, such as recordings of calls and video;
• Professional or employment-related information, such as your work history and previous employer;
• Education information, such as student records and directory details;
• Inferences drawn from any of the Personal Information listed above to build a profile about a person, for example their preferences and characteristics.

We may share your personal information with a third party for a business purpose. When we share information for a business purpose, we sign a contract that sets out the purpose and requires the recipient both to keep that personal information confidential and to use it only to perform the contract.

Personal information does not include:

• Information that is publicly available from government records.
• Consumer information that has been de-identified or aggregated.
• Information that falls outside the CCPA’s scope, such as:
• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), or clinical trial data;
• Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

 

Sensitive Personal Information can include a Social Security number, driver’s license or state identification number, financial account and access credentials, precise geolocation data, or racial or ethnic information. BestCitizenBank does not use or disclose Sensitive Personal Information for any purpose beyond those permitted under applicable law.

We collected this Personal Information from the following categories of sources:

• Directly from a California resident or from their representatives
• Service providers, consumer data resellers and other third parties
• Public records (federal, state or local government sources)
• Website or mobile app activity, and social media
• Third parties or institutions acting at the direction of a client or prospect
• Corporate clients, about the individuals connected with them (for example, an employee or board member)

The categories of third parties with whom we shared Personal Information for the business purposes described in this privacy disclosure are:

• Vendors and service providers
• Third parties that you or your agents authorize us to share your personal information with, in connection with the products or services we provide to you.
• Other third parties who help customers carry out activity online and on mobile devices, and who support mortgage and fulfillment services
• Government agencies, as laws and regulations require

 

How we use Personal Information

• Providing services, including maintaining or servicing accounts, looking after customers, processing or fulfilling orders and activity, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytics, or providing similar services.
• Spotting security incidents, guarding against malicious, deceptive, fraudulent or illegal activity, and pursuing those responsible for it.
• Short-term, transient use where the information is not shared with a third party and is not used to build a profile or otherwise alter a consumer’s experience beyond the current interaction.
• Auditing related to a current interaction and concurrent activity.
• Checking and maintaining the quality or safety of a service controlled by us, and improving, upgrading or enhancing that service.
• Debugging to find and repair errors that impair existing intended functionality.
• Carrying out internal research for technological development and demonstration.
• Complying with laws and regulations, and with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes or opinions)
• Evaluating or carrying out a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or a similar proceeding, in which personal information held by us is among the assets transferred.

 

Sale of Personal Information

In the past 12 months, we have not “sold” Personal Information subject to the CCPA/CPRA, including Personal Information of minors under the age of 16. In this Disclosure, “sold” means sharing Personal Information with a third party for money or other valuable consideration.

 

Your rights under the CCPA/CPRA

If you are a California resident, you have the following rights over your Personal Information:

• Right to Know
  You can ask us to tell you, free of charge, the categories and the specific pieces of Personal Information we have collected about you over the past 12 months. You can also ask about the categories of sources the Personal Information came from, the business or commercial purpose for collecting it, and the categories of third parties we shared it with.
• Right to Correct
  You can ask us to correct Personal Information we hold about you that is not accurate.
• Right to Delete
  You can ask us to delete Personal Information that we collected from you, subject to certain legal or regulatory exceptions.
• Right to Opt Out of Sale or Sharing of Personal Information:
• You can opt out of the sale or sharing of your Personal Information. If we sell or share any of your Personal Information, you may tell us at any time to stop. As of the date this Disclosure was last updated, BestCitizenBank does not sell or share any Personal Information.• Right to Limit the Use and Disclosure of Sensitive Personal Information
  You can ask us to limit our use and disclosure of your Sensitive Personal Information to those uses permitted by applicable law.
• Right to Non-Discrimination
  You will not be treated differently for exercising any of your CCPA/CPRA rights.
• We will confirm that we have received your request and tell you how long we expect it will take to respond. A request for specific pieces of Personal Information needs extra verification of your identity, to protect against unauthorized access. We will make good-faith efforts to respond within 45 days, and may extend that by a further 45 days where reasonably necessary.
• Google Analytics
• We use Google Analytics (GA) for aggregated, anonymized analysis of website traffic. To track your session usage, Google places a cookie (_ga) with a randomly-generated ClientID in your browser. That ID is anonymized and contains no identifiable information such as email, phone number or name. We also send Google your IP Address. We use GA to track aggregated website behavior, such as which pages you looked at, for how long, and so on. This information matters to us for improving the user experience and working out how effective the site is.
• If you would rather not be monitored, please delete your _ga cookies and install the Google Analytics Opt-Out Browser Add-On."

 

How to exercise your rights

If you are a California resident, you can send us a request by:

1. Filling in our online Personal Information Request Form
2. Calling 888.673.1808

 

Questions or concerns

If you have questions or concerns about this Disclosure or our practices, you can reach us by:

1. Writing to us at:
   BestCitizenBank Headquarters
   601 S. Figueroa St. 47^th Floor
   Los Angeles, CA 90017
   
2. Sending an email to Service Inquiries

 

Changes to this Disclosure

We may change or update this Disclosure from time to time. When we do, we will post the revised Disclosure on this page with a new “Last Updated” date.