Privacy Policy for California Residents

This Privacy Policy for California Residents (“Policy”) supplements the information
contained in Rivo Holdings, LLC’s (“Rivo” or “company” or “we” or “us” or “our”)
Privacy Policy and applies solely to all visitors, users, and others who reside in
the state of California (“consumers” or “you”), except for RIVO employees whose
personal information is collected and processed in the context of their employment
or work relationship with RIVO. We adopt this notice to comply with the California
Consumer Privacy Act (CCPA), as amended, and any terms defined in the CCPA shall
have the same meaning when used in this Policy.

Information We Collect

We collect information that identifies, relates to, describes, references, is
reasonably capable of being associated with, or could reasonably be linked,
directly or indirectly, with a particular consumer, household, or device
(“personal information”). Personal information does not include:

• Publicly available information from government records, through widely distributed media, or that the consumer made publicly available without restricting it to a specific audience.
• Lawfully obtained, truthful information that is a matter of public concern.
• Deidentified or aggregated consumer information.
• Information excluded from 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
  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information
from consumers within the last twelve (12) months:

Sensitive Personal Information Categories Chart

Sensitive personal information is a subtype of personal information consisting of
the specific information categories listed in the chart below. Importantly, the
CCPA only treats this information as sensitive personal information when we
collect or use it to infer characteristics about a consumer.

The chart below identifies which sensitive personal information categories, if
any, we have collected from consumers to infer characteristics about them in the
last 12 months.

We obtain the categories of personal information listed above from the following
categories of sources:

• Directly from you. For example, from forms or applications you complete, or from services that you use or purchase from us.
• Indirectly from you. For example, from observing your actions on our Website, social media platforms, and mobile interactions.
• From third parties that interact with us in connection with the products and services we provide, such as credit bureaus and financial institutions, as well as advertising networks and data analytics providers.
• From our affiliates.
• From other customers such as referral programs.

Use of Personal Information

We may use, sell, or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. If you provide your personal information to purchase a product or service from us, we will use that information to process your request.
• To meet our obligations and enforce our rights arising from any agreements with you, including for billing or collections, or to comply with legal requirements.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate an address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases, and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulation.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct 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 similar proceeding, in which personal information held by us about our Website users and consumers is among the assets transferred.

Use of Sensitive Personal Information

We may use or disclose sensitive personal information for the following statutorily approved reasons (Permitted SPI Purposes):

• Performing actions that are necessary for our consumer relationship and that an average consumer in a relationship with us would reasonably expect.
• Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
• Defending against and prosecuting those responsible for malicious, deceptive, fraudulent, or illegal actions directed at the Company.
• Ensuring physical safety.
• Short-term, transient use, such as non-personalized advertising shown as part of your current interactions with us, where we do not:
  • disclose the sensitive personal information to another third party; or
  • use it to build a profile about you or otherwise alter your experience outside your current interaction with the Company.
• Services performed for the Company, including maintaining or servicing accounts, processing or fulfilling transactions, verifying consumer information, processing payments, or providing financing, analytic services, storage, or similar services for the Company.
• Activities required to:
  • verify or maintain the quality or safety of a product, service, or device that we own, manufacture, had manufactured, or control; or
  • improve, upgrade, or enhance the service or device that we own, manufacture, had manufactured, or controlled.
• Collecting or processing sensitive personal information that we do not use for the purpose of inferring characteristics about a consumer.

We do not use or disclose sensitive personal information for purposes other than
the Permitted SPI Purposes. Subject to your limitation rights, the additional
sensitive personal information use purposes include all of the purposes described
in the Personal Information Collection, Use, and Disclosure Purposes section. For
more on your right to limit these additional sensitive personal information use
purposes, see the Your Rights and Choices section below.

Additional Categories or Other Purposes

We will not collect additional categories of personal information or use the
personal information we have collected for materially different, unrelated, or
incompatible purposes without providing you notice. If required by law, we will
also seek your consent before using your personal information for a new or
unrelated purpose.

We may collect, process, and disclose aggregated or de-identified consumer
information for any purpose, without restriction. When we collect, process, or
disclose aggregated or deidentified consumer information, we will maintain and use
it in deidentified form and will not attempt to reidentify the information, except
to determine whether our deidentification processes satisfies any applicable legal
requirements.

Disclosing, Selling, or Sharing of Personal Information

Business Purpose Disclosures

We disclose the above categories of personal information, including sensitive
personal information, to service providers and contractors and third parties as
set forth above in the Use of Personal Information Section to support our business
functions, or as required or permitted by law, including with:

• Our affiliates and subsidiaries;
• Service providers, including financial institutions such as Plaid;
• Third parties to whom you authorize us, directly or indirectly, to disclosing your personal information in connection with the products or services we provide to you; and
• Governmental or regulatory authorities, as required by law.

These disclosures are made to deliver products and services purchased from us, to
support customers with using our products and services, including online account
management and troubleshooting, and/or to deliver location-based advertising. We
only make these business purpose disclosures under written contracts that describe
the purposes, require the recipient to keep the personal information confidential,
and prohibit using the disclosed information for any purpose except performing the
contract.

Selling or Sharing Personal Information

We may sell your personal information, including sensitive personal information,
to third parties, subject to your rights to opt-out of those sales, but have not
sold it in the preceding 12 months. We may share your personal information with
third parties for cross-context behavioral advertising purposes, and have shared
your personal information in the preceding 12 months. Our personal information
sales do not include information about individuals who we know are under age 16.
While we have not sold any personal information in the preceding 12 months, we may
do so in the future, which may include all categories of personal information and
Sensitive personal information which we collect as identified above, and which may
be sold to the following categories of third parties.

• Advertising networks
• Internet service providers
• Data analytics providers
• Government entities
• Operating systems and platforms
• Social networks
• Data brokers or aggregators
• Banks, credit unions, or other institutions offering financing
• Payment processors and collection agencies

These sales are made to learn more about our customers and increase company
revenue. In order to exercise your rights to opt out of the sale of your personal
information, click here.

Your Rights and Choices

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 Know and Data Portability

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 12 months (the
“right to know”), including the specific pieces of personal information we have
collected about you (a “data portability request”). Once we receive your request
and confirm your identity (see Exercising Your Rights to Know or Delete), 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 that personal information.
• If applicable, if we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • Sales, identifying the personal information categories that each category of recipient purchased; and
  • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• The specific pieces of personal information we collected about you (also called a data portability request).

Right to Delete and Right to Correct

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 (the “right to
delete”). Once we receive your request and confirm your identity (see Exercising
your Rights to Know or Delete), we will review your request to see if an exception
allowing us to retain the information applies. We will delete or deidentify
personal information not subject to one of the following exceptions from our
records and will direct our service providers to take similar action.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

You also have the right to request correction of personal information we maintain
about you that you believe is inaccurate (the “right to correct”). We may require
you to provide documentation, if needed, to confirm your identity and support your
claim that the information is inaccurate. Unless an exception applies, we will
correct personal information that our review determines is inaccurate and notify
our service providers to take appropriate action.

Right to Limit Sensitive Personal Information Use

You have a right to ask businesses that use or disclose your sensitive personal
information to limit those actions to just the CCPA’s Permitted SPI purposes (the
“right to limit”).

Personal Information Sales or Sharing Opt-Out

You have the right to request that businesses stop selling or sharing your personal
information at any time (the “right to opt-out”). Similarly, the CCPA prohibits
businesses from selling or sharing the personal information of consumers it
actually knows are under 16 years old without first obtaining consent from
consumers who are between 13 and 15 years old or the consumer’s parent or guardian
for consumers under age 13 (the “right to opt-in”). For more information on
exercising your opt-out rights, see How to Exercise
Your Rights.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you with a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that
can result in different prices, rates, or quality levels. Any CCPA-permitted
financial incentive we offer will reasonably relate to your personal information’s
value and contain written terms that describe the program’s material aspects.
Participation in a financial incentive program requires your prior opt-in consent,
which you may revoke at any time.

How to Exercise Your Rights

Exercising Your Rights to Know or Delete or Correct

To exercise your rights to know, delete, or correct as described above, please submit a request by either:

• Calling us at: 619-436-1100
• Emailing us at: privacy@rivoholdings.com

Exercising Your Right to Limit or Opt-Out

In order to exercise your rights to opt out of the sale of your personal
information, click here. You may also email
privacy@rivoholdings.com. You can also
submit your request to opt-out of personal information sales and sharing through an
opt-out preference signal.

Responding to Your Requests to Know, Delete, or Correct

We will confirm receipt of your request within ten business days. We endeavor to
substantively respond to a verifiable request within 45 days of its receipt. If we
require more time (up to another 45 days), we will inform you of the reason and
extension period in writing. We will deliver our written response to your verified
email address. Our substantive response will tell you whether or not we have
complied with your request. If we cannot comply with your request in whole or in
part, we will explain the reason, subject to any legal or regulatory restrictions.
Applicable law may allow or require us to refuse to provide you with access to some
or all of the personal information that we hold about you, or we may have
destroyed, deleted, or made your personal information anonymous in compliance with
our record retention policies and obligations.

Any disclosures we provide will cover information for the 12-month period
preceding the request’s receipt date. We will consider requests to provide longer
disclosure periods that do not extend past January 1, 2022, unless providing the
longer timeframe would be impossible or involves disproportionate effort.

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 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.

Verification Process and Authorized Agents

Only you, or someone legally authorized to act on your behalf, may make a request
to know or correct or delete related to your personal information. You may also
make a request to know or delete on behalf of your child by contacting us via
telephone or email at the contact information identified above.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• 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.

You do not need to create an account with us to submit a request to know or
delete. We will only use personal information provided in the request to verify
the requestor’s identity or authority to make it.

Response Timing and Format

In response to your request to limit or opt-out, we will process your request, as
soon as feasibly possible, but no later than 15 business days from the date we
receive the request. Once you make a request to limit or opt-out, we will wait at
least 12 months before asking you to reauthorize the use or disclosure of your
sensitive personal information for purposes other than the Permitted SPI Purposes
or personal information sales or sharing.

Changes to our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any
time. When we make changes to this privacy policy, we will post the updated notice
on the Website and update the notice’s effective date. Your continued use of our
Website following the posting of changes constitutes your acceptance of such
changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Rivo
Holdings collects and uses your information described here and in the 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: