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CCPA Privacy Notice

Privacy Notice for California Residents

Effective Date: January 1, 2020

The Privacy Notice for California Residents (“Privacy Notice”) supplements the information contained in our
Privacy Policy, and applies solely to visitors, users and others who reside in the State of California
(“consumers” or “you”). This Privacy Notice addresses your rights under the California Consumer Privacy
Act of 2018 (“CCPA”); any terms defined in the CCPA have the same meaning when used in this Privacy
Notice. You can download a printable copy of this Privacy Notice here.

This Site and our Services collect information that identifies, relates to, describes, references, is capable of
being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or
device (“personal information”). In particular, the Site collects or may have collected the following
categories of personal information in the last twelve (12) months. We obtain the categories of personal
information listed below as set forth in the methods described in the Information We Collect section of the
Privacy Policy.

We may collect the following categories of personal information:
• Identifiers. Such as a real name, alias, postal address, unique personal identifier, online
identifier, Internet Protocol address, email address, account name, or other similar identifiers.
• Personal information categories listed in the California Customer Records statute (Cal. Civ.
Code § 1798.80(e)). Such as name, signature, physical characteristics or description, address,
telephone number, passport number, driver’s license or state identification card number, insurance
policy number, education, employment, employment history, bank account number, credit card
number, debit card number, or any other financial information, medical information, or health
insurance information. Some personal information included in this category may overlap with other
• Commercial information. Such as records of personal property, products or services purchased,
obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other similar network activity. Such as browsing history, search history, information
on a consumer’s interaction with a website, application, or advertisement.

We may use or disclose the personal information we collect for one or more of the business purposes
indicated in the How We Use Your Information section of our Privacy Policy.
We will not collect additional categories of personal information or use the personal information we collected
for materially different, unrelated, or incompatible purposes without providing you notice.

We may disclose your personal information to a third party for a business purpose. When we disclose
personal information for a business purpose, we enter a contract that describes the purpose and requires
the recipient to both keep that personal information confidential and not use it for any purpose except
performing the contract. We share your personal information with the categories of third parties listed in the
How We Share Information section of our Privacy Policy.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for
a business purpose:
• Identifiers
• California Customer Records personal information categories
• Commercial information
• Internet or other similar network activity
We do not sell personal information. In the event that we do sell any personal information, we will update
this Privacy Policy to list the categories of consumers’ personal information sold.

The CCPA provides consumers (California residents) with specific rights regarding their personal
information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Access Specific Information and Data Portability Right
You have the right to request that we disclose certain information to you about our collection and use of
your personal information over the past twelve (12) months. Once we receive and confirm your verifiable
consumer request, we will disclose to you:
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability
• If we disclosed your personal information for a business purpose, the business purpose for which
personal information was disclosed, and the personal information categories that each category of
recipient obtained.

Right to Delete
You have the right to request that we delete any of your personal information that we collected from you
and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request,
we will delete (and direct our service providers to delete) your personal information from our records, unless
an exception applies.

Exercising Your Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable
consumer request to us by either:
• Calling us at (206) 971-3773
• Sending us an e-mail at

For submissions via email please use the downloadable Verifiable Consumer Request Form
Only you, or a person registered with the California Secretary of State that you authorize to act on your
behalf, may make a verifiable consumer request related to your personal information.
You may only make such a request for access or data portability twice within a 12-month period. 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, and describe
your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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. Making a verifiable
consumer request does not require you to create an account with us. 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 endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we
require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will
deliver our written response electronically. Any disclosures we provide will only cover the 12-month period
preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons
we cannot comply with a request, if applicable. For data portability requests, we will select a format to
provide your personal information that is readily useable and should allow you to transmit the information
from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive,
repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why We
made that decision and provide you with a cost estimate before completing your request.

We will not discriminate against you for exercising any of your CCPA rights.

If you have any questions or comments about this notice, the ways in which we collect and use your
information described in this Privacy Policy, your choices and rights regarding such use, or wish to exercise
your rights under California law, please do not hesitate to contact us at

Phone: (206) 971-3773
Postal Address: Strategic Income Management, LLC
Attention: Legal Department
1200 Westlake Ave N
Suite #713
Seattle, WA 98109.