Privacy Policy

Casco Financial Inc. – Last updated on Monday, January 24th, 2022

I. Introduction

CASCO Financial, Inc. (“CASCO Financial” or “us” or “we”) respects your privacy. This Privacy Policy (this “Policy”) describes our policies and practices with respect to our collection, protection, use, and sharing of personally identifiable information (“PII”). For purposes of this Policy, PII about you (the “User”) means information that describes, identifies, references, relates to, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) with you or your communications device(s) (e.g. computer, mobile phone, tablet, etc.). We commit to using PII responsibly and safeguard it according to our detailed security standards. In no event thereunder, do we sell your (or others’) PII.

We may add to, change, or delete the terms of the Policy from time to time. When we make changes, we will post the amended policy on our website at https://verdevista.tempurl.host (the “Website”). Any changes to the Policy will become effective immediately upon our posting of the Policy, and your use of the Website and our services is deemed to consitute your agreement with the Policy terms. Please be sure to review (e.g. check) the Policy prior to providing us with PII. We encourage you to review the Policy (in its entirety) carefully and thoughtfully, as it relates to your experience with CASCO Financial, from the outset when exploring a potential partnership to applying for an Investment Registration or Loan Application, processing payment via the ACH Payment Gateway, and including the introduction of additional services that support your evolving financial and investment needs.

If you are, or apply to become, a customer (including borrower or new client) of CASCO Financial with respect to products or services to be used primarily for business, family, household, or personal purposes, you have additional privacy rights, as reflected in the Client Privacy Notice available at https://verdevista.tempurl.host/client-privacy.

II. How

How does CASCO Financial Collect Your Personally Identifiable Information (PII)? What Types Of Personally Identifiable Information (PII) Do We Collect? CASCO Financial collects PII about you when you actively provide it to us, such as by completing an online form, providing PII at your discretion or responding to a request for information, and/or when you interact with us online (e.g. browsing our website). For example, if you decide to opt-in to any of our communications options, such as receiving emails at an email address you provide, we will collect the email address and any additional PII that you may send to us via email address or other communication methods (such as newsletters, if applicable, and physical mail).

We may collect PII about you from the following sources: our affiliates; the internet, including social media platforms and websites; other financial institutions with whom you have accounts (if you choose to elect to have an account aggregation service); conferences; the press or other print media; credit reporting agencies; and other persons (including persons who you may refer us to for a possible customer relationship) and organizations as permitted under applicable law of the State of California.

We may collect PII, including payment data, necessary to process your payment via the Wells Fargo ACH Payment Gateway, utilizing the Plaid Account Validation Service (AVS) and interface for automated authorization. All payment data and information is stored by Wells Fargo. You may access, find, and reference the Plaid, Inc. Privacy Policy at https://plaid.com/legal/#consumers. You may access, find, and reference the Wells Fargo Privacy Policy at https://www.wellsfargo.com/privacy-security.

Not all information that is collected from you is PII. In addition, we may collect information about you that we cannot use to specifically identify you. Listed below are the types of information about you that we may collect or have collected within the past twelve (12) months. These types of information are considered PII only if the information describes, identifies, references, relates to, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) with you or your communications and/or electronic device.

• Identifiers. Identifiers such as your name, online identifier, postal address, Internet Protocol (IP) address, account name, email address, driver’s license number, passport number (if applicable), Social Security number, and/or other similar identifiers.
• Internet Or Other Similar Network Activity. Internet (or other similar network) Activity, such as an advertisement, browsing history, mobile application(s), search history, or information about your computer or device, including Media Access Control (MAC) addresses, browser type, computer type (and brand), device manufacturer (and model), language, operating system name and version, and screen resolution used. It may also include (when applicable) mobile application usage data (e.g. the date and time our mobile application on your communication and/or electronic device accesses our servers) and what information and/or files have been downloaded to the application.
• Commercial Information. Commercial Information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Customer Records Information. Customer Records Information where all in part of in full, may be considered identifiers or professional (e.g. employment) such as name, address, driver’s license (or state identification card number), education, employment and employment history, passport number (if applicable), signature, Social Security number, bank account number, or any other financial information, health insurance information, or medical information (if applicable).
• Geological Data. Geological Data means the physical location or movements of the communication and/or electronic device you may use to connect with us online. If you use the mobile application, the physical location of your communication and/or electronic device through the use of Bluetooth, cellphone towers, satellites, Wi-Fi signals or other similar technologies (for example).
• Personal Characteristics. Personal Characteristics that are related to classification(s) legally protected from discrimination, such as age, ethnicity, gender, marital status, national origin, and race. Professional Or Employment – Related Information.
• Professional or Employment – Related Information may allude to, include or reference to your current or past job history.
• Sensory Data. Sensory Data means audio, electronic, visual or similar information.

III. Personally Identifiable Information

Our Business Purposes For Collecting Personally Identifiable Information (PII) And How We Use The Information. We may use the PII we collect from you for a variety of purposes permitted by law, including:

• To allow you to access features within our website when you request those features.
• To allow you to apply for our services and to evaluate your eligibility for such services, including your creditworthiness.
• To communicate with you, including in response to your inquiries and to fulfill your requests, as well as to inform you of any changes made to the terms and conditions relating to the services received from us or to the CASCO Financial Services (also referred to as “Services”) in which you are enrolled.
• To improve the interface of our services and the functionality of such services offered.
• To maintain (and potentially upgrade) the security of the services, including any data or relevant information collected.
• To personalize our services for you by presenting CASCO Financial Services and offers tailored specifically to you.
• To prevent fraud through confirmation and validation of your identity and/or location. For example, if you are conducting a payment transaction, we may use your communication and/or electronic device’s physical location for fraud prevention purposes.
• To provide you with information about our Services and to provide you with our Services, including to service loans and investments we may make to you and for you with your consent.
• For purposes such as compliance, legal, and risk management, including to monitor our compliance practices with fair lending laws, state laws, and regulations.
• Other legally permissable (or everyday business purposes), including data analysis, product development, and compliance with law enforcement as well as any other applicable legal processes.

IV. Sharing

When And With Whom Do We Share Personally Identifiable Information (PII). We may share the PII we collect with our affiliates (as permitted by applicable law) and with our current service providers. We may engage service providers to deliver services to you on our behalf, such as bill payment, check processing, money transfers, payment solutions, and wiring services (if applicable or necessary); and to assist us with technology support, operational support, and/or any other forms of assistance required. We bind our service providers to protect the confidentiality and security of the PII that we share with them.
We may also share PII with others as we deem necessary (or appropriate), consistent with applicable laws, and for the following purposes:

(a) to comply with applicable legal requirements (such as responding to subpoenas) and regulatory requirements (such as the monitoring of fair lending law compliance); (b) to enforce and investigate violations of applicable Terms and Conditions;
(c) to protect our rights, including the right to privacy, property or safety, and/or that of our affiliates, you or others;
(d) to respond to requests from public and government authorities;
(e) to allow us to pursue available remedies or limit the damages that we may sustain; and
(f) to conduct or evaluate a merger, assignment, divestiture, joint venture, reorganization, restructuring, sale, transfer or other disposition of all or any portion of our business, including assets or stock.

Disclaimer: We do not share PII with non-affiliated entities for those entities to use for their own marketing purposes, and in no event, do we sell PII.

V. Other

Other Information Collection, Sharing, And Use

We may also collect, share, and use the information classified and is not identified as PII as follows:

• Aggregated Data. We may compile or create (or have compiled or created through our service providers) aggregated data consisting of pieces of information from various sources, including information collected by cookies, from accounts, transaction information, and any other information including PII, which does not personally identify you or any other individual. We may use and share this aggregated data for our business purposes only, including data analytics, marketing products and services, research, and other business or legal purposes.
• Data From Cookies And Tags. We (including our service providers) may use cookies – defined as pieces of data that are stored in memory on the user’s (of the internet) device. In addition, we may use tags, which tie to cookies and allow us to manage the data and information gathered from the cookies. We use these specific technologies to collect such information as browser type, pages visited, the time spent on each page, and which tasks a user performs while on a particulat page. Furthermore, we use this information to help improve your overall online experience with us; to improve (and update) the user interface(s) of our Website and mobile applications; for security purposes; to display personalized or specified products and offers that are tailored to you; to personalize your service(s); and to recognize you and your communications and/or electronic device to ensure you can access our online products and services (if and when applicable). You may change these settings within (or on) your Internet browser to automatically decline cookies; to automatically delete cookies upon exiting the Internet browser; or to give you the choice (or option) of accepting or declining the cookies from a particular. Should you choose not to accept cookies from our Website, you may experience reduced functionality (or functionalities) or other inconveniences while accessing and using the Website platform and/or other online products and services (if applicable).
• HubSpot Technologies. We use (data) analytics, automation via forms and marketing, and other corresponding technological services provided by HubSpot, Inc. HubSpot, Inc. uses cookies and similar technology (or technologies), which allow us to analyze and capture information (willingly provided by users with their direct consent) about the users of the specified services. To access and obtain the privacy practices of HubSpot, Inc. and learn more, please reference : https://legal.hubspot.com/privacy-policy. HubSpot, Inc. offers its partners and users the ability to opt out of certain data collection practices. To access and obtain the security practices of HubSpot, Inc. and learn more, please reference : https://legal.hubspot.com/security.
• Plaid Technologies. We use an automated Account Validation Service (AVS), data analytics, and other corresponding technological services provided by Plaid, Inc. This financial technological (“FinTech” or “fintech”) tool uses cookies and other related technologies to allow us to analyze and capture information (willingly provided by users with their direct consent) about the users of the specified services as well as the acknowledged authorization of all financial data processed (e.g. via ACH Payment Gateway). To access and obtain the privacy practices of Plaid, Inc. and learn more, please reference : https://plaid.com/legal.
• Wells Fargo (Visa CyberSource) Payment Gateway. We use an automated payment gateway API, data analytics, and other corresponding technological services provided by Wells Fargo Financial Services via Visa CyberSource. This financial technological (“FinTech” or “fintech”) tool uses cookies and other related technologies to allow us to analyze information and process fintech services. To access and obtain the privacy practices and security practices regarding the collection and use of data information through the Wells Fargo (Visa CyberSource) Payment Gateway, please reference : https://www.wellsfargo.com/privacy-security/ and https://usa.visa.com/legal/privacy-policy.html

VI. Security Information

We seek to use reasonable administrative, organizational, and technological measures to (help) prevent unauthorized access to any of your PII and protect the PII we maintain within our organization. In addition to the safeguards applied by us to protect your PII, there are several steps you can take to protect your PII as well (such as maintaining them in a secure location and never sharing your passwords). The steps you take to compliment the numerous safeguards we apply are particularly important. Should you have reason to believe that your interaction with us is no longer secure, please notify us immediately of the concern or issue by contacting us at (408) . 354 . 9777.

VII. Control

Control Over Your Personally Identifiable Information (PII) Should you desire or want to update your PII provided willingly to us, you may contact us directly through one of the means listed within the ‘How To Contact Us’ section below. Please note that certain information is required to provide such requested services where particular requests to delete (all or any) required information may result in our inability to provide such services.

VIII. Privacy Rights

California Resident’s Privacy Rights

If you are a resident of California, then you have certain rights to privacy under the California Consumer Privacy Act (referenced as “CCPA”). CASCO Financial, Inc. honors such rights (as described herein) and are prohibited by law from discriminating against you (the Client or user) for exercising any of those rights. a.

• Right To Know Subject to the exemption and exceptions mentioned below, if you are a resident of the state of California, then you have the right to know (i) the categories of third parties, excluding service providers with whom we have shared the PII during the past twelve (12) months; (ii) what PII we have collected about you; and (iii) why we have collected the information. Please reference the section entitled, “How To Submit A Request”. You may request that we provide a description of the categories of the PII collected (e.g. a “Catgories Request”) or a request for access to the specified pieces of PII collected (e.g. a “Specific Pieces Request”).If you create, make, and submit a Categories Request, then we will need to verify your identity to a reasonable degree of certainty. A reasonable degree of certainty may include you providing us with at least two (2) elements of data primarily specific to you to ensure we can verify your identity properly and authentically. Upon confirmation that your request is a verifiable consumer request, we will disclose to you:
• Our business or commerical purpose for collecting such PII;
• The categories of PII we collected about you;
• The catgories of sources for the PII we collected about you, including government records available to the public and/or social media platforms and websites; and
• The categories of third parties other than service provider(s) (if any) with whom we shared the PII.If you create, make, and submit a Specific Pieces Request, then we will need to verify your identity to a reasonably high – degree of certainty. A reasonably high – degree of certainty may include you providing us with at least three (3) elements of data primarily specific to you to ensure we can verify your identity properly and authentically. Upon confirmation that your request is a verifiable consumer request, we will disclose to you:
• The specific pieces of PII we collected about you that you have requested.2.  Right To Request Decision You are entitled to the right to request that we delete any of your PII that we collected from you and retained aside from (e.g. exclusion of or other than) the Personal Customer Information (as defined throughout). We are not obligated to comply with your request should we have a legal basis to retain the PII. Should you create, make, and submit a request for us to delete the PII (and you do not hold an account of any type with us), then we may require you to provide us with at least two (2) elements of data primarily specific to you to ensure we can verify your identity properly and authentically. Upon confirmation that your request is a verifiable consumer request, we will inform you whether we have deleted (and have directed our service partners and providers to delete) your PII from our records, or whether we are declining to grant your request to delete due to an exception of the CCPA Deletion Requirements.3. ExceptionsCertain PII is protected by federal and state privacy law(s) regardless of the CCPA, thus the specific rights described therein do not apply in the case of that particular PII. More specifically:
• If you are (or apply to become) a Client (or customer) of CASCO Financial, Inc. (with respect to our products and/or Services used primarily for family, household, or personal purposes), the non – public PII we obtain from you in that particular context (referred to as “Personal Customer Information”) is protected under other federal and state law rather than the CCPA. As stated herein, the rights of such Clients and users of CASCO Financial, Inc. are set forth in our Client Privacy Notice available at https://verdevista.tempurl.host/client-privacy.
• If you are working for CASCO Financial, Inc. or if you are an employee or other representative of a business (or other organization) that is engaging in or exploring a business – to – business (also known as “B2B”) transaction(s) with CASCO Financial, Inc., then the CCPA does not provide you with the privacy rights described within this “Section VII. California Resident’s Privacy Rights”.3. How To Submit A Request To request access to or deletion of your PII (as aforementioned above), please submit a verifiable consumer request to CASCO Financial, Inc. by one of the two (2) methods listed below:

• Contacting us via telephone at (408) . 354 . 9777
• Contacting us via physical mail and sending your request to :
  CASCO Financial, Inc.
  15700 Winchester Boulevard
  Los Gatos, CA 95030

To receive additional instructions on how to request access to or deletion of your PII, you may select to email CASCO Financial, Inc. at support@verdevista.tempurl.host.

Please note that you may create, make, and submit a request on your own behalf. We do not collect any PII related to or directly correlating to minors, including anyone under the age of eighteen (18). Should you decide to designate an authorized agent to make a request on your behalf, then please provide CASCO Financial, Inc. with a signed declaration stating your intent to permit that individual to act on your behalf and include the first and last name of the individual, address, email address, and telephone number. This will ensure we, with full authorization, will act in accordance with the requests of that individual.

To protect your PII from unauthorized disclosure or deletion at the request of someone other than you or your legal representative, CASCO Financial, Inc. requires proper identification and verification prior to granting any request to provide copies of, provide (additional or further) information regarding (e.g. know more about), or delete your PII. We take special precautions to help ensure this. More specifically, we require that any request submitted to us:

• Describes your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.
• Provides sufficient information to allow us to reasonably verify if you are the person (individual) about whom we collected the PII or an authorized representative.

Please note and understand that we cannot respond to your request(s) or provide you with the PII if we cannot verify your identity or verify your authority to make the request and confirm that the PII relates to you. We endeavor to respond to a verifiable consumer request within forty – five (45) days of its’ receipt. If we require additional time (up to 45 additional days), then we will inform you of the extension period and reason for the extension in written form. We will only use the PII provided in a verifiable consumer request to verify the identity of the requestor or the authority to make the request.

IX. Information Retention

We retain information, including PII, for as long a period as necessary to achieve the purpose for which it was collected, to fulfill contractural or legal obligations, or for as long as permitted by applicable law. We may retain aggregated or de – identified information indefinitely.

X. Scope

Scope Of Clients And Users

Our online products and services, including our Website, are not directed (in any way) to users under the age of thirteen (13). We do not knowingly collect any PII online from any individual we know to be under the age of thirteen (13). Our online products and services, including our Website and mobile applications, are designed for users from (and are controlled and operated by us from) the United States of America. In using our own online product(s) and service(s), you consent to the transfer of your information to the United States of America, which may have different data protection rules and regulations than those of your country (if applicable).

XI. Tracking

Do Not Track Signals

Your Internet browser may allow you to send CASCO Financial, Inc. a “Do Not Track Signal” to communicate your privacy preferences. Our website currently does not respond to browser Do – Not – Track Signals.

XII. Links

Links To Other Websites

Our mobile applications and Website may feature (hyper)links to third – party websites that offer goods, information, or services. When you click on or select one (1) of these links, you will be accessing content and services that are not subject to this Policy. We are not responsible for the information – collection practices of other websites that you may visit and urge you to review their privacy policies prior to providing them with any PII. Third – party services or Websites may collect, secure, and use information about you in a way that is different from those described herein (within this Policy).

XIII. Contact

Should you have any questions regarding this Policy, you can

• call CASCO Financial, Inc. at (408) . 354 . 9777
• email us at support@verdevista.tempurl.host
• or write to us at:

CASCO Financial, Inc.
15700 Winchester Boulevard
Los Gatos, CA 95030

Privacy Notice

Casco Financial Inc. – Last updated on Tuesday, February 1st, 2022

WHY?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing.
Federal law also requires us to tell you how we collect, protect, and share your personal information. Please read this notice carefully to understand what we do.

WHAT?

The types of personal information we collect and share depend on the product(s) or service(s) you have with us. This information can include:

• Social Security Number & Employment Information
• Account Balance(s) & Transaction History
• Employment Information

HOW?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customer’s personal information; the reasons CASCO Financial, Inc. chooses to share; and whether you can limit this sharing.

REASONS WE CAN SHARE YOUR PERSONAL INFORMATION	DOES CASCOFI SHARE?	CAN YOU LIMIT THIS SHARING?
FOR OUR EVERYDAY BUSINESS PURPOSES Such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus.	YES	NO
FOR OUR MARKETING PURPOSES With service providers we use to offer our products and services to you (please see below to limit the ways in which we contact you).	YES	NO
FOR JOINT MARKETING WITH OTHER FINANCIAL COMPANIES	YES	WE DO NOT SHARE
FOR OUR AFFILIATES’ EVERYDAY BUSINESS PURPOSES Information about your transactions and experiences	YES	NO
FOR OUR AFFILIATES’ EVERYDAY BUSINESS PURPOSES Information about your creditworthiness	YES	YES
FOR OUR AFFILIATES TO MARKET TO YOU	YES	YES
FOR OUR NONAFFILIATES TO MARKET TO YOU	NO	WE DO NOT SHARE

TO LIMIT OUR SHARING

CALL (408) 354 – 9777 Where Our Operator Will Prompt You Through Your Choices Please Note: If you are a new customer, we can begin sharing your information thirty (30) days from the date we sent this notice. When you are no longer our customer, we can continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

QUESTIONS?

CALL (408) 354 – 9777

WHO WE ARE/WHO IS PROVIDING THIS NOTICE?

CASCO Financial, Inc.

WHAT WE DO

HOW DOES CASCOFI PROTECT MY PERSONAL INFORMATION?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We conduct periodic reviews of our computer systems, including security features. Additionally, our employees are required to acknowledge their responsibilities to maintain the confidentiality of Customer Information.

HOW DOES CASCOFI COLLECT MY PERSONAL INFORMATION?

We collect your personal information, for example, when you

• Apply For An Investment Or Loan via Online Forms (e.g. New Client Information, New Investor Questionnaire, etc.)
• Make ACH Payments From The Website ACH Payment Gateway
• Seek Advice About Your Investments

We also collect your personal information from others, such as affiliates, credit bureaus, or other companies.

WHY CAN’T I LIMIT ALL SHARING?

Federal law gives you the right to limit only:

• Affiliates from using your information to market you
• Sharing for affiliates’ everyday business purposes – information about your creditworthiness
• Sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

WHAT HAPPENS WHEN I LIMIT SHARING FOR AN ACCOUNT I HOLD JOINTLY WITH SOMEONE ELSE?

Your choices will apply individually unless you tell us otherwise.

Any account holder may express a privacy preference on behalf of the other joint account holders.

DEFINITIONS

AFFILIATES

Companies related by common ownership or control. They can be financial and non-financial companies.

Our affiliates include companies with a CASCO Financial, Inc. name, of which there are none.

NONAFFILIATES

Companies not related by common ownership or control. They can be financial and non-financial companies.

CASCO Financial, Inc. does not share with nonaffiliates so they can market to you.

JOINT MARKETING

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

CASCO Financial, Inc. does not jointly market.

STATE LAWS MAY GIVE YOU ADDITIONAL RIGHTS TO LIMIT SHARING FOR CALIFORNIA

In accordance with California State Law, we will not share information we collect about you with nonaffiliates, except as permitted by law, such as with your consent or to service your accounts.

Additional Information

• You will receive a separate form entitled Important Privacy Choice for California Consumers. (Privacy Policy)
• For additional information about California Residents’ Financial Privacy Rights, go here