Privacy Policy

Last Updated: January 1, 2020

  1. Introduction. We at Trinity Capital Management, LLC (“We,” “Us” or “Uppercase Capital”) respect your privacy and are dedicated to protecting your personal information through our compliance procedures entailed in this Privacy Policy (“Policy”). Please study the following information carefully as it details the type of information we may collect from you or that you may provide to us when you visit uppercasecapital.org (“Website”), and our practices for collecting, using, maintaining, protecting, and disclosing such information. This Policy applies to information we collect (i) on this Website; (ii) in e-mail, text and other electronic communications sent between you and this Website; (iii) when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.

    If you do not agree with our Policy and practices regarding how Uppercase Capital handles your personal information, you should not use our Website. Accessing or using this Website signifies and confirms your acceptance of the terms set forth in this Policy. This Policy may change from time to time in our sole discretion. Accordingly, you should visit this Website and review the Policy periodically to determine if any changes have been made. The date on which this Policy was last updated will be noted immediately above this Policy.

  2. Information We Collect. In the course of using this Website, we may collect personal information and data to (i) present you with credit monitoring services, financial products and/or other tailored products; (ii) present the contents of this Website to you; (iii) deliver services that you have requested; (iv) communicate with you via telephone, email, postal mail, and/or text message from us, our marketing partners, and/or other third parties; (v) display advertising tailored to you interests or background; (iv) perform data and statistical analysis from your use of this Website; (v) enforce our Terms and Conditions; and (vi) perform any other functions otherwise described to you when you provide us with your information.. Any collection of personal information or data through this Website is performed with your consent.

    Personally Identifiable Information. We may collect Personally Identifiable Information (“PII”) that you directly provide to us that can identify you, including, but not limited to, your first and last name, physical address, telephone number, cellular number, social security number, email address, date of birth, driver’s license number, state of residency and information pertaining to your bank account.

    Non-Personally Identifiable Information. We also collect information automatically as you navigate through this Website. We use log files and cookies to collect Non-Personally Identifiable Information (“Non-PII”) including, but not limited to, the IP address of the computer or mobile device making the request, browser type and the times you access this Website and usage details. Please note that IP addresses are not usually associated with your personal computer, but with a portal through which you accessed the Internet. Consequently, IP addresses are not linked to personally identifiable information.

    Cookies. As you navigate through and interact with this Website, we may use automatic data collection technologies (“Cookies”) to collect certain information, including but not limited to, information about your equipment, browsing actions and patterns, operating system, internet connection and location data. The information we collect automatically may include personal information, and we may maintain it or compound it with personal information we collect in other ways or receive from third parties. Cookies help us improve this Website so we are able to deliver a better and more personalized experience by reducing unwanted information that you might otherwise receive.

  3. How We Use Your Information. We use the information that we collect about you through your interaction with this Website as well as information that you provide to us, including personal information. This information is used (i) to present the contents of this Website to you; (ii) to deliver services that you have requested; (iii) to determine whether to extend an offer to become an Affiliate or Advertiser in our Network; (iv) to communicate with you via telephone, email, postal mail, and/or text message from us, our marketing partners, or other third parties; (v) to display advertising tailored to your interests or background; (vi) perform data and statistical analysis from your use of this Website; (vii) enforce our Terms and Condition; and (viii) to perform any other functions otherwise described to you when you provide us with your information.

  4. Disclosing Your Information. As a general rule, Uppercase Capital will not share, sell or otherwise distribute your personal information without your consent. However, Uppercase Capital may disclose personal information that we collect or you provide as described in this Policy (i) to fulfill the purpose for which you provide your information; (ii) for any other purpose disclosed by Uppercase Capital when you provide us your information; (iii) to protect the rights of Uppercase Capital and/or any third parties; (iv) to third party service providers who assist us in operating this Website, conducting our business or serving our users, so long as such information is kept confidential; (v) with affiliated entities; (vi) to comply with any court order, law, legal process, and/or government or regulatory request; (vii) as part of a liquidation or bankruptcy proceeding, to a buyer or other successor in the event of a merger, reorganization, dissolution or divestiture of some or all of Uppercase Capital’s assets.

  5. Data Retention and Security. By accessing and navigating through this Website, you hereby acknowledge and agree that Uppercase Capital may retain your information indefinitely. Please note that any transmission of personal information is at your own risk.

    Commitment to Online Security. Uppercase Capital uses commercially reasonable efforts to protect the security of your personal information and encrypt sensitive information such as your social security number, driver license number and bank account information. Although we strive to provide reasonable security measures for your personal information that we process and maintain, we cannot guarantee the security of your personal information transmitted to and through this Website.

    No Liability for Acts of Third Parties. Uppercase Capital will exercise all reasonable efforts to safeguard the confidentiality of your personal information. However, transmissions protected by industry standard security technology and implemented by human beings cannot be made absolutely secure. Consequently, Uppercase Capital shall not be liable for unauthorized disclosure of personal information due to no fault of Uppercase Capital including, but not limited to, errors in transmission and unauthorized acts of third parties.

  6. Third Party Links. This Website may contain links to third party websites, which may have independent privacy policies that differ from our own. We are not responsible, nor do we endorse, any of the activities and practices that take place on third party websites. Accordingly, we recommend that you review the privacy policy posted on any third party website thoroughly before disclosing any personal information.

  7. Consent to Communicate. When you submit your personal information to this Website, you are providing your express consent to be contacted via email, telephone, postal mail or text message communication. If you wish to opt-out of one or all of these communication methods, please follow the instructions provided in the corresponding communication.

  8. Modifications or Amendments. From time to time, we may change this Policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice to you if these changes are material on this Website, and where required by applicable law, we will obtain your consent. For your information, the date this Policy was last updated is listed at the top of this page. Your continued use of this Website after any such changes have been made signifies and confirms your acceptance of any changes or amendments to this Policy.

  9. Children Under the Age of 18. This Website is not intended for children under eighteen (18) years of age. No one under 18 years of age may access or provide any information on this Website. We do not knowingly collect personal information from children under 18 years of age.

  10. California Disclosures. California Law requires us to provide certain disclosures to users of this Website.

    Shine the Light Disclosure. Civil Code Section 1798.83 permits California residents that use this Website to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at support

  11. support@uppercasecapital.org.

    Do Not Track Disclosures. Business and Professions Code Section 22575(b) requires websites to disclose their practices with respect to the use of tracking technology made by third parties and whether this Website honors web browser do-not-track signals. No third parties are able to collect personally identifiable information you provide on this Website. At this time, Uppercase Capital does not respond to do-not-track browser settings or signals.

  12. Your Rights Under the CCPA. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

    Disclosure of Personal Information We Collect About You

    You have the right to know:

    • The categories of personal information we have collected about you;

    • The categories of sources from which the personal information is collected;

    • Our business or commercial purpose for collecting or selling personal information;

    • The categories of third parties with whom we share personal information, if any; and

    • The specific pieces of personal information we have collected about you.

    • Please note that we are not required to:
      • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;

      • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or

      • Provide the personal information to you more than twice in a 12-month period.

    Personal Information Sold or Used for a Business Purpose

    In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale [or disclosure] of your personal information. If you exercise your right to opt-out of the sale [or disclosure] of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale [or disclosure] of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link here:
    http://uppercasecapital/ccpa-delete

    Right to Deletion

    Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

    • Delete your personal information from our records; and

    • Direct any service providers to delete your personal information from their records.

    • Please note that we may not delete your personal information if it is necessary to:

    • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

    • Debug to identify and repair errors that impair existing intended functionality;

    • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

    • Comply with the California Electronic Communications Privacy Act;

    • 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

    • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

    • Comply with an existing legal obligation; or

    • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

    Protection Against Discrimination

    You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things

    • Deny goods or services to you;

    • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

    • Provide a different level or quality of goods or services to you; or

    • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

    Please note that we may charge a different price or rate or provide a different level or quality of [goods and/or services] to you, if that difference is reasonably related to the value provided to our business by your personal information.

  13. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

  14. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please:

    • Complete a data subject request form available on our website at:
      HTTP://WWW.UPPERCASECAPITAL.ORG/CCPA-REQUEST

    • Email to us at support@uppercasecapital.org

      Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period. If you choose to contact directly by website, email, or in writing, you will need to provide us with:

      • Enough information to identify you: your full name, address and phone number so we can identify you

      • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and

      • A description of what right you want to exercise and the information to which your request relates.

    We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

    Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

AFFILIATE DISCLOSURE - Uppercase Capital may get a commission from retail offers.