California Consumer Privacy Act (“CCPA”) Privacy Policy

Last Updated: August 2026

This California Consumer Privacy Statement (“Statement”) supplements the Cascade365 Web Privacy Policy. This Statement applies solely to California consumers, including California residents who interact with us in a business capacity, whose personal information is processed by the Cascade 365 Group of Companies, including Cascade Capital, LLC; Cascade Capital Funding, LLC; and Cascade Receivables Management, LLC (each a “Cascade365 Company,” and collectively, “Cascade365,” the “Cascade365 Companies,” “we,” or “us”).

This Statement applies to personal information the Cascade365 Companies collect about California consumers, both online and offline.

This Statement does not apply to:

• Cascade365 Companies’ personnel or job applicants;
• Information collected, processed, or disclosed in connection with the provision of financial products or services pursuant to the U.S. Gramm-Leach-Bliley Act and its implementing regulations (“GLBA”) or the California Financial Information Privacy Act. If you have a financial product or service with a Cascade365 Company, we will use and share the personal information we collect from or about you in accordance with our U.S. Consumer Privacy Notice.

This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and their implementing regulations (collectively, the “CCPA”).

1. Notice of Collection and Use of Personal Information

In the preceding 12 months, one or more Cascade365 Companies may have collected the following categories of personal information about consumers:

• Identifiers: name, business name, postal address, email address, telephone number, title, Social Security number, account number, area of inquiry, and other similar identifiers. We receive this information from original creditors and other entities from whom accounts are purchased, service providers engaged to provide location and collection services, directly from consumers, and directly from business customers and prospective business customers through our website.
• Information described in Cal. Civ. Code § 1798.80(e): insurance policy information, bank account information, other financial information, medical information, and health insurance information. We receive this information from original creditors and other entities from whom accounts are purchased, and directly from consumers.
• Professional or employment-related information: We receive this information from original creditors, credit reports, third-party data providers, and directly from consumers.
• Internet or electronic network activity: IP address, browser type and settings, device identifiers, pages visited, and dates and times of visits to our websites or payment portals. We collect this information through automated technologies when you interact with our online services.
• Audio and electronic information: call recordings created when a consumer has a telephone conversation with us.
• Geolocation data: location information, including GPS coordinates obtained from process servers in connection with litigation.
• Inferences: information derived from the categories above to create a profile reflecting preferences, characteristics, behavior, or similar attributes.

We may use your personal information for the following business purposes:

• Servicing accounts and collecting debts
• Processing payments and fulfilling transactions
• Verifying consumer information
• Providing customer service and responding to inquiries
• Auditing compliance with applicable laws and regulations
• Maintaining security and integrity of our systems and services
• Identifying and repairing errors that impair functionality
• Conducting internal research for service development and improvement
• Responding to inquiries from business customers and prospective business customers
• Managing business-to-business relationships and providing information about our services
• Carrying out our obligations and enforcing our rights under contracts with consumers, business customers, and our clients
• Responding to law enforcement requests and complying with applicable law, court orders, and governmental regulations
• Complying with attorney ethical obligations
• As otherwise described to you at the time of collection

We do not collect or process sensitive personal information for the purpose of inferring characteristics about California consumers covered by this Statement. To the extent we process deidentified information, we will maintain and use such information in deidentified form and will not attempt to reidentify it unless permitted by applicable law.

2. Retention of Personal Information

We retain personal information for the period reasonably necessary to achieve the purposes described in this Statement and our Web Privacy Policy, consistent with applicable statutes of limitation, attorney ethical obligations, and federal and state records retention requirements.

3. Sources of Personal Information

During the preceding 12 months, we may have obtained personal information from the following categories of sources:

• Original creditors and other entities from whom accounts are purchased
• Service providers engaged to provide location, collection, and related services
• Credit reporting agencies and third-party data providers
• Directly from consumers (via telephone, mail, email, and our websites and payment portals) and directly from business customers and prospective business customers through forms on our website
• Government entities
• Internet service providers and analytics providers (through automated technologies)

4. Sale or Sharing of Personal Information

The Cascade365 Companies do not sell consumers' personal information to third parties for marketing or advertising purposes and do not share personal information for cross-context behavioral advertising purposes.

In the ordinary course of business, a Cascade365 Company may transfer personal information in connection with the sale or transfer of account portfolios to third-party purchasers who acquire the rights, title, and interest to such accounts. This information is collected, processed, and disclosed in connection with the provision of financial services and is exempt from the CCPA pursuant to the Gramm-Leach-Bliley Act (Cal. Civ. Code § 1798.145(e)).

5. Disclosure of Personal Information for a Business Purpose

During the preceding 12 months, we may have disclosed the following categories of personal information for a business purpose to the following categories of third parties:

Category of Personal Information	Categories of Third-Party Recipients
Identifiers	Service providers engaged for collection, location, and account servicing; professional services organizations (law firms, auditors); data analytics providers
Information described in Cal. Civ. Code § 1798.80(e)	Service providers engaged for collection and account servicing; professional services organizations
Professional or employment-related information	Service providers engaged for collection and account servicing
Internet or electronic network activity	Service providers engaged for website hosting and analytics
Audio and electronic information	Service providers engaged for collection services; professional services organizations
Geolocation data	Service providers engaged for process serving and litigation support
Inferences	Service providers engaged for collection and account servicing Service providers engaged for website hosting, analytics, and CRM or marketing services (if applicable) Business contact information

We may also disclose personal information to government entities in response to law enforcement requests or in connection with legal proceedings, and to third parties in connection with actual or proposed corporate transactions such as mergers, acquisitions, or portfolio sales.

6. California Consumer Privacy Rights

Subject to certain limitations and exceptions under the CCPA, California consumers have the following rights:

Right to Know: You have the right to request, twice in a 12-month period, that we disclose to you the categories of personal information collected about you; the categories of sources from which personal information was collected; the business or commercial purpose for collecting, selling, or sharing personal information; the categories of third parties to whom personal information was disclosed; and the specific pieces of personal information collected about you.

Right to Correction: You have the right to request that we correct inaccurate personal information we maintain about you.

Right to Deletion: You have the right to request that we delete personal information we have collected from you, subject to certain exceptions under the CCPA.

Right to Opt-Out of Sale or Sharing: You have the right to opt out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising. As described above, the Cascade365 Companies do not sell personal information for marketing or advertising purposes and do not share personal information for cross-context behavioral advertising. Because the Cascade365 Companies do not sell personal information (other than transfers exempt under the Gramm-Leach-Bliley Act) and do not share personal information for cross-context behavioral advertising, opt-out preference signals such as Global Privacy Control are not applicable to our processing of your personal information at this time. If our practices change, we will update this Statement and honor such signals as required by law.

Right to Limit Use of Sensitive Personal Information: Where applicable, you have the right to limit our use and disclosure of sensitive personal information to purposes authorized under the CCPA. We do not use or disclose sensitive personal information for purposes beyond those specified in the CCPA regulations.

7. How to Submit a Request

To submit a request to know, correct, delete, or opt out, you may:

• Submit the applicable webform at the bottom of this page;
• Call us at 866-723-1187;
• Email us at ccpa@cascade365.com; or
• Download and complete the applicable request form and mail it to:

Cascade365
Attn: CCPA Response Team
5341 Old Redwood Hwy, Suite 220
Petaluma, CA 94954

Please identify the Cascade365 Company to which your request is directed:

• Cascade Capital, LLC
• Cascade Receivables Management, LLC
• Cascade Capital Funding, LLC

8. Verification

To protect your privacy and security, we will verify your identity before responding to your request. We will match information you provide against the personal information we maintain. To verify your request, you must provide the following, as applicable:

• Last 4 digits of your Social Security number (required)
• Your county of residence
• Last 4 digits of the original creditor account you were contacted about
• Your name
• Your address
• Your personal email address

If you request specific pieces of personal information, you must also submit a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

The Cascade365 Company receiving your request will confirm receipt within 10 days unless a substantive response is provided within that timeframe. We will respond to your request within 45 days of receipt. If additional time is reasonably necessary, we will notify you and may take up to an additional 45 days (90 days total) to respond.

9. Authorized Agents

You may designate an authorized agent to submit a request on your behalf. To do so, you must provide either a valid power of attorney or signed written authorization to the agent, and the agent must present that documentation to the Cascade365 Company receiving the request. We may also require you to verify your identity directly with us.

10. Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising your privacy rights under the CCPA.

11. Contact Us

If you have questions or concerns about this Statement, or if you wish to receive it in an alternative format, please contact us at 866-723-1187 or ccpa@cascade365.com.

To open a PDF version of this Privacy Policy that you can print or download, please click on this link.