First Foundation Inc. California Consumer Privacy Act (“CCPA”) Disclosure
Definitions
The following terms you will see in this First Foundation Inc. CCPA POLICY are defined below:
“We” “our” and “us” means First Foundation Inc.
“You” “your” or “consumer” refer to a natural person who is a California Resident
“Personal Information” “PI” or “Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. “Personal Information” does not include information that is publicly available (which means information that is lawfully made available from federal, state, or local government records).
Collection of Personal Information
Below is a list of categories of personal information we have collected about consumers in the preceding 12 months. For each category identified we have also provided the categories of sources from which we collected the personal information, the business or commercial purpose for collecting the information, and the categories of third parties with whom we share the personal information
Purposes. The business and commercial purposes for which we collect personal information as disclosed below are defined as follows:
- Employment Processing: Means to use personal information in order to perform services in connection with a consumer’s role, responsibility, and/or status as a job applicant to or an employee, owner, director, officer, or contractor of First Foundation Inc. This includes but is not limited to administering payroll or benefits, maintaining compliance with internal policies and procedures, and to comply with applicable federal and state employment laws.
- Operational Processing: Means to use personal information in order to perform services and enforce our rights in connection with the financial products or services we provide, including but not limited to, opening, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying information, processing payments, providing financing, advertising or marketing other products and services to you or other similar activities.
- Security Purposes: Means to use personal information to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity.
- Internal Research & Development Purposes: Means to use personal information to undertake internal research activities to verify or maintain the quality or safety of a service that is owned or controlled by us and to develop, verify, improve, upgrade, or enhance our services.
- Marketing Purposes: Means to use personal information to market our products and services.
- Auditing Purposes: Means to use personal information in connection with activities to audit and/or achieve compliance with our policies and procedures or applicable legal and regulatory standards.
- Debugging Purpose: Means the use of personal information for debugging to identify and repair errors that impair existing intended functionality of our services.
Categories of Personal Information We Collect |
Categories of Sources from Which We Collect the PI |
Our Business or Commercial Purpose for Collecting the PI |
Categories of Third Parties with Whom We Share the PI |
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Identifiers (such as real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers) |
From you directly or those acting on your behalf when you [use our services], apply for a job with us or when acting as an employee, owner, director, officer or contractor of First Foundation Inc. Government entities. Job listing websites. |
Employment Processing, Security Purposes, Financial Processing, Internal Research & Development Purposes, Auditing Purposes, Marketing Purposes. |
Government entities. The service providers we utilize to operate our financial products and to perform services and administer benefits to job applicants, employees, owners, directors, officers and contractors of First Foundation Inc. The operating systems and platforms our business runs on. |
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Categories of Personal Information described in California Civil Code Section 1798.80(e). (This includes any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, 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) |
From you directly or those acting on your behalf when you use our services, apply for a job with us or when acting as an employee, owner, director, officer or contractor of First Foundation Inc. Government entities. Job listing websites. |
Employment Processing, Security Purposes, Financial Processing, Internal Research & Development Purposes, Auditing Purposes, and Marketing Purposes. |
Government entities. The service providers we utilize to operate our financial products and to perform services and administer benefits to job applicants, employees, owners, directors, officers and contractors of First Foundation Inc. The operating systems and platforms our business runs on. |
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Characteristics of protected classifications under California or federal law. |
From you directly or those acting on your behalf when you use our services, apply for a job with us or when acting as an employee, owner, director, or contractor of First Foundation Inc. Government entities. Job-listing websites. |
Employment Processing, Security Purposes, Auditing Purposes, and Internal Research & Development Purposes. Financial Processing |
Government entities. The service providers we utilize to operate our financial products and to perform services and administer benefits to job applicants, employees, owners, directors, officers and contractors of First Foundation Inc. The operating systems and platforms our business runs on. |
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Commercial information (such as records of personal property, products or services purchased, obtained or considered or other purchasing or consuming histories or tendencies). |
From you directly when you use our services, apply for products. Government entities. |
Financial Processing and Internal Research & Development Purposes. |
Government entities. The service providers we utilize to operate our financial products and to perform services and administer benefits to job applicants, employees, owners, directors, officers and contractors of First Foundation Inc. The operating systems and platforms our business runs on. |
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Biometric information [Items 19; 39-41 of HR Questionnaire and Security Cameras and Fingerprints in IT Questionnaire] |
From you directly when acting as an employee, owner, director, officer or contractor of First Foundation Inc. Security Cameras in our branch locations. |
Employment Processing, Security Purposes, Auditing Purposes, Internal Research & Development Purposes and Financial Processing. |
Government entities. The service providers we utilize to [operate financial products] and to perform services and to administer benefits to job applicants, employees, owners, directors, officers and contractors of First Foundation Inc. The operating systems and platforms our business runs on. |
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Internet or other electronic network activity information |
From you directly or other acting on your behalf when you use our online services, such as our online banking platform. |
Employment Processing, Security Purposes, and Auditing Purposes |
Our internet service providers and operating systems and platforms. |
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Geolocation Data |
N/A |
N/A |
N/A |
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Audio, electronic, visual thermal, olfactory, or similar information |
Security Cameras in our branch locations. From you directly or those acting on your behalf when calling for assistance with Commercial Client Services and Digital Banking, calls are recorded. |
Security Purposes, and Auditing Purposes. Financial processing. |
Government entities. Law enforcement. The service providers we rely on to provide financial products and services and to administer benefits in connection with a consumer’s role, responsibility and/or status as a job applicant to or an employee, owner, director, officer or contractor of First Foundation. The operating systems and platforms our business runs on. |
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Professional or employment-related information |
From you directly when you [use our services] apply for a job with us or when acting as an employee, owner, director, officer or contractor of First Foundation. From individuals that you list as referrals in your application for employment. Job listing websites. |
Employment Processing, Security Purposes, Auditing Purposes and Internal Research & Development Purposes. Financial Processing. |
Government entities. The service providers we utilize to [operate our financial products] and to perform services and administer benefits to job applicants, employees, owners, directors, officers and contractors of First Foundation Inc. The operating systems and platforms our business runs on. |
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Education Information |
From you directly when you [use our services], apply for a job with us or are acting as an employee, owner, director, officer or contractor of First Foundation. |
Employment Processing, Security Purposes, Auditing Purposes and Internal Research & Development Purposes. Financial Processing. |
Government entities. The service providers we rely on to provide financial products and services and to administer benefits in connection with a consumer’s role, responsibility and/or status as a job applicant to or an employee, owner, director, officer or contractor of First Foundation. The operating systems and platforms our business runs on. |
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Inferences drawn from any of the information identified above. |
N/A |
N/A |
N/A |