Privacy
Policy

PRIVACY AND SECURITY STATEMENT As we say on the “About Us” page of our main website, our commitment to you and your business is to be honest, responsive and loyal. One of the ways we honor that commitment is by attempting to be transparent about our personal information collection practices. Our privacy statement, contained in the pages that follow, serves to give notice about the types of personal information we collect, how we use it, who we share it with and why, and what we do to try to protect it. We delve into those matters in a fair amount of detail in the pages that follow. We encourage you to read them carefully. In the meantime, we provide a quick overview below. This privacy statement was amended as of February 24, 2020 and is effective as of that date. Summary of how we handle Personal Information     You can use the links below to navigate to areas of this statement that apply specifically to you, or which may otherwise be of interest: Some Important Vocabulary What Personal Information Do We Collect? How Do We Use the Personal Information We Collect? When/With Whom Do We Share Personal Information? Your Privacy Choices We Do What We Can to Ensure Information Security Children’s Privacy Data Privacy and Protection Laws Changes To This Privacy Statement Contacting Us   Some important vocabulary Although not itself a contract, this privacy statement is an important document that explains how we address some of our legal obligations and your related legal rights involving personal information. Clarity is, therefore, important. We’ll use this section to let you know about some words that have special meanings whenever you see them in this statement. Let’s start with the word “statement” itself: when we reference “this statement”, “this privacy statement” and “our statement”, we mean the Privacy and Security Statement you are reading now. We use the words “you” and “your” to mean you, the reader, and other visitors to our online and mobile resources who are, in all cases, over the age of 18. This age requirement is discussed in more detail here. When we refer to “Clear Skies”, “we”, “us” or “our”, throughout this statement, we are referring to Clear Skies Capital, Inc. When we talk about our “online and mobile resources”, we mean all websites, portals or other features we operate to allow you to interact with us and our systems, as well as the mobile apps we’ve created and distributed to let you interact with the content we provide. An “affinity action” is when you “follow” us, “like” us or take a similar or analogous action on our external social media presence. Finally, and perhaps most importantly, when we refer to “personal information”, we mean information that can be used to identify or easily be linked to you. The privacy laws in some jurisdictions include unique elements in what they consider to be the personal information of the data subjects they protect. If those laws apply to us, then when the context requires, our use of the phrase “personal information” includes the unique elements required by such laws.What personal information do we collect? If you visit and/or use our online and mobile resources, we collect and retain certain personal information through automated/technical means. We describe that automatic collection here. In addition to that, if you choose to participate in, or make use of certain activities and features available via our online and mobile resources, you will need to provide us with information about yourself. We describe that type of voluntary submission immediately below. By using our online and mobile resources, you are signifying to us that you agree with this section of our privacy statement and that we may use and disclose your information as described. Voluntarily Submitted Information. Here are some of the ways you voluntarily give us your personal information. The types of personal information you will be submitting to us in these situations is typically limited to identifiers such as your name, email address, mailing address and/or phone number. You can read about how we use that personal information here.

• Emails, Chat, and Texts – If you choose to send us a message from our “Contact Us” page or by using our application forms located on the home page and the apply page, you will be giving us your name, phone number and email address and any other personal information that may be in your message or attached to it. The same is true if you send us a text message or use the chat feature on our online and mobile resources.
• Creating Accounts; Signing up for Newsletters – If we make an account creation feature available to the general public (that is, to visitors/users who are not our customers or workforce members) you will be giving us at least your name and email address and potentially other identifiers such as your phone number. The same is true if you sign up to receive a newsletter or other informational or marketing material we publish.
• Applying for a Loan – Our online and mobile resources can be used to apply to become customer of our loan or other services. When you submit such an application, you provide us with certain personal information including your name, email address and phone number. We discuss how we use this personal information here. If you become a customer of our service offerings, you will be required to enter into an agreement. That agreement is separate from both this statement and our related website Terms of Use and will have its own terms and conditions governing our use of your personal information, confidentiality, data privacy and data security. As a result, those terms and not this statement will apply.
• Applying for an Open Position – If you are interested in applying for an open position with us, our online and mobile resources allow you to submit your resume and cover letter. In making such submission, you will be providing us with your name, email address and any other personal information you choose to include. We discuss how we use this personal information here.

If you prefer we not receive the above-described personal information, please don’t submit it. This means you shouldn’t participate in the applicable activities on, or use the applicable features available from, our online and mobile resources. Such participation and use is strictly your choice. By not participating, you may limit your ability to take full advantage of the online and mobile resources, but most of the online and mobile resources content will still be available to you. Automatically Collected Information; Cookies When you visit or use our online and mobile resources, basic information about your internet/electronic activity is automatically collected through your browser via tracking technologies, such as “cookies.” As just about everyone knows by now, cookies are small text files downloaded onto your computer or mobile device. We collect minimal information about your computer or mobile device via cookies in order to recognize your computer or mobile device and store some information about your preferences for using our online and mobile resources or past actions, such as:

• your IP address
• the type of browser and operating system you use
• the date and time and length of your visit
• the pages visited, graphics viewed and any documents downloaded
• links to other sites you accessed from our online and mobile resources or used to navigate to our online and mobile resources

Additional information about cookies and tracking technologies is available here. If you access our online and mobile resources from a phone or other mobile device, the mobile services provider may transmit to us certain information such as uniquely identifiable mobile device information. That, in turn, allows us to collect mobile phone numbers and associate them with the mobile device identification information. Some mobile phone service providers also operate systems that pinpoint the physical location of devices and we may receive this geolocation data as well. Finally, when you use our online and mobile resources, we allow third party service providers to place their own cookies or similar technologies in order to engage in the same types of collection we describe above. For example, we use third party “web analytics” services such as those offered by Google Analytics. We have also implemented third-party advertising features that use the data collected from cookies and similar technologies to provide you relevant online advertising when you visit other sites. For more information on how Google specifically uses this data, go to www.google.com/policies/privacy/partners/. You can learn more about how to opt out of Google Analytics by going to https://tools.google.com/dlpage/gaoptout and about your choices related to targeted advertising and how to opt out of receiving such targeted advertisements by going to http://www.networkadvertising.org/choices/. User Beware: External Sites, Apps, Links and Social Media. We maintain a presence on one or more external social media platforms such as Twitter, Facebook, YouTube and LinkedIn and our online and mobile resources may contain links to other websites or apps controlled by third parties. We are not responsible for either the content on, or the privacy practices of, social media platforms, or any third party sites or apps to which we link. Those apps, sites and platforms are not controlled by us and therefore have their own privacy policies and terms of use. To be clear: neither this statement nor the terms of use appearing on or in any of our online and mobile resources apply to our social media presence or any third party sites or apps to which we may link. That means even if you take an affinity action on our specific social media presence, and identifiers about you are automatically collected and given to us as a result, that collection and transfer is governed by the privacy policies and other terms of the applicable social media platform and are not our responsibility. If you have questions about how those apps, sites and platforms collect and use personal information, you should carefully read their privacy policies and contact them using the information they provide. How do we use the personal information we collect? We use personal information we collect only in the manner and through the means allowed by applicable law. That means we determine whether we have a lawful basis/legitimate business purpose to use your personal information before doing so. As stated in applicable law, such lawful bases/legitimate business purposes include receiving express consent, operating our business, performing a contract, and complying with a legal obligation. We use the automatically collected personal information described here to compile generic reports about popular pages/features of our online and mobile resources, to see how users are accessing our online and mobile resources, and to display targeted advertisements on other sites you visit. We use the personal information you voluntarily submitted, as described here, to:

• respond back directly to you and/or send you the information you requested or about which you inquired, or that we believe you may be interested in
• customize our programs and newsletters to make them more relevant to you prevent fraud and perform similar security related activities
• conduct an cursory evaluation of your eligibility if you submitted a loan application and determine which of our services may be appropriate for your situation
• evaluate the candidacy of job applicants, process their applications and communicate with them regarding their application, all in accordance with applicable law
• manage, administer and perform under our contracts with our vendors and business partners, or share information with them about our products and services

We do not sell or rent personal information automatically collected by, or which you voluntarily provide when using our online and mobile resources. When/with whom do we share personal information? We may share your personal information as described below. Affiliates We may share personal information to our corporate affiliates who will use such information in the same way as we can under this statement. Legal Requirements We may disclose personal information to government authorities, and to other third parties when compelled to do so by such government authorities, or at our discretion or otherwise as required or permitted by law, including responding to court orders and subpoenas. To Prevent Harm We also may disclose such information when we have reason to believe that someone is causing injury to or interference with our rights or property, or harming or potentially harming other persons or property. Business Sale/Purchase If Clear Skies or any of our affiliates who may be covered by this statement sell or transfer all or substantially all of their assets, equity interests or securities, or are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, divestiture, consolidation, or liquidation, personal information may be one of the transferred assets. Vendors and Business Partners We also share personal information with those of our vendors and business partners who need it to perform under the contracts we have with them. Such vendors include those from whom we obtain technology and infrastructure services to host our online and mobile resources and communications services that allow us to interact with our customers via voice, text and other methods. Your privacy choices If we are using your personal information to send you marketing materials, such as newsletters or product alerts via text or email, you may opt out by following the opt-out instructions in the email or other communication (e.g., by responding to the text with “STOP”). When we receive your request, we will take reasonable steps to remove your name from our distribution lists, but it may take time to do so. You may still receive materials for a period of time after you opt out. In addition to opting out, you have the ability to access, amend and delete your personal information by contacting us using the contact information below. Opting out of or changing affinity actions or other submissions or requests made on our external social media presence will likely require that you do so directly on that applicable social media platform as we do not control their procedures. Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not specifically respond to browser “do not track” signals. Things happen: we do what we can to ensure information security We will take all reasonable security precautions to protect your personal information provided to our online and mobile resources by implementing reasonable safeguards appropriate to the type of personal information collected. Due to the inherently open and somewhat risky nature of the Internet, however, we cannot guarantee that your information, whether during transmission or while stored on our systems or otherwise in our care, will be free from unauthorized access or that loss, misuse, destruction, or alteration will not occur. We disclaim any liability for any theft or loss of, unauthorized access or damage to, or interception of any data or communications. You should also note that vendors and business partners we engage to provide us with services either to help us in our business, or to perform functions we would otherwise perform ourselves, will have access to your information, including your personal information, as part of the work they perform. We require that they enter into confidentiality and other agreements, but cannot guarantee their compliance. Children’s privacy Federal law imposes special restrictions and obligations on commercial website operators who direct their operations toward, and collect and use information from children under the age of 13. We take those age-related requirements very seriously, and, consistent with them, do not intend for our online and mobile resources to be used by children under the age of 18, and certainly not by anyone under the age of 13. Moreover, we do not knowingly collect personal information from minors under the age of 18. If we become aware that anyone under the age of 18 has submitted personal information to us via our online and mobile resources, we will delete that information and not use it for any purpose whatsoever. We encourage parents and legal guardians to talk with their children about the potential risks of providing personal information over the Internet. Submitting information from outside the united states We control and operate the online and mobile resources from within the United States of America (the “U.S.”). Information collected through the online and mobile resources may be stored and processed in the United States or any other country in which we or our vendors maintain facilities. Although we do not actively block or monitor visitors from other countries, the online and mobile resources are directed only at visitors from the U.S. As such, this privacy statement is consistent with U.S. law and practice and is not adapted to other laws (including European data security and privacy laws). Clear Skies will apply the applicable laws of the U.S. including as embodied in this privacy statement in place of data protections under your home country’s law. That is, you freely and unambiguously acknowledge that this privacy statement, not your home country’s laws, controls how we will collect, store, process, and transfer your personal information. Similarly, the English language version of this privacy statement is the controlling version regardless of any translation you may attempt. Data privacy and protection laws: the ccpa and gdpr Privacy and data protection laws vary around the world and among the several United States. Some of those laws are more specific than others. Most prominently, residents of California and data subjects whose personal information was obtained from them while they were in the European Economic Area, United Kingdom, and Switzerland have certain additional rights in cases where the party collecting that information is governed by the applicable law. We have reviewed our business operations and data-related business practices with legal counsel in the context of the General Data Protection Regulation under European Law also known as the “GDPR” and the California Consumer Privacy Act (the “CCPA”). As a result of that review, as of the effective date of this statement, we do not believe we are governed by either the GDPR or CCPA. We do not, for instance, collect personal information from data subjects in the European Economic Area, United Kingdom, or Switzerland or elsewhere abroad. Similarly, we do not target or tailor our online and mobile resources or any of our other US-based business activities to appeal to, or specifically attempt to do business in those jurisdictions. In terms of California, although we obviously do business within the state, we do not meet any of the various statutory thresholds and criteria that would bring us under the CCPA. For general visitors, consumers and regulators who have questions about whether or how the GDPR, CCPA or other industry- or jurisdiction-specific laws apply to us, you can contact us using the contact information found here. Changes to this privacy statement We reserve the right to change or update this statement from time to time. Please check our online and mobile resources periodically for such changes since all information collected is subject to the statement in place at that time. Typically, we will indicate the effective/amendment date at the beginning of this statement. If we feel it is appropriate, or if the law requires, we’ll also provide a summary of changes we’ve made near the end of the new statement. Contacting us If you have questions about our privacy statement or privacy practices, please contact us at:

• Address Clear Skies Capital Attn: Privacy Office 11858 Bernardo Plaza Ct Ste 110 San Diego, CA 92128
• Email: info@clearskiescapital.com
• Phone: 1-800-230-9822