PRIVACY NOTICE
CLICK HERE FOR FULL WEB VERSION
Last updated January 01, 2022
This privacy notice for TCW Capital Finance LLC (“Company,” “we,” “us,” or “our”), describes how and why we might
collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:
Visit our website at http://www.tcwcapitalfinance.com, or any website of ours that links to this privacy notice
Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not
agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please
contact us at info@tcwcapitalfinance.com.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these
topics by clicking the link following each key point or by using our table of contents below to find the section you
are looking for. You can also click here to go directly to our table of contents.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal
information depending on how you interact with TCW Capital Finance LLC and the Services, the choices you make, and the
products and features you use. Click here to learn more.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we receive any information from third parties? We do not receive any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for
other purposes with your consent. We process your information only when we have a valid legal reason to do so.
Click here to learn more.
In what situations and with which parties do we share personal information? We may share information in specific
situations and with specific third parties. Click here to learn more.
How do we keep your information safe? We have organizational and technical processes and procedures in place to
protect your personal information. However, no electronic transmission over the internet or information storage technology
can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other
unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your
information. Click here to learn more.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have
certain rights regarding your personal information. Click here to learn more.
How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject request form
available here, or by contacting us. We will consider and act upon any request in accordance with applicable data protection
laws.
Want to learn more about what TCW Capital Finance LLC does with any information we collect? Click here to review the
notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about
us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your
interactions with us and the Services, the choices you make, and the products and features you use. The personal
information we collect may include the following:
names
phone numbers
email addresses
Sensitive Information. We do not process sensitive information.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes
to such personal information.
Information automatically collected
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In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is
collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal
your specific identity (like your name or contact information) but may include device and usage information, such as your IP
address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country,
location, information about how and when you use our Services, and other technical information. This information is primarily
needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use
to access the Services. Depending on the device used, this device data may include information such as your IP
address (or proxy server), device and application identification numbers, location, browser type, hardware model,
Internet service provider and/or mobile carrier, operating system, and system configuration information.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security
and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services,
including:
To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries
and solve any potential issues you might have with the requested service.
To send you marketing and promotional communications. We may process the personal information you send to
us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our
marketing emails at any time. For more information, see “WHAT ARE YOUR PRIVACY RIGHTS?” below).
To deliver targeted advertising to you. We may process your information to develop and display personalized
content and advertising tailored to your interests, location, and more.
To protect our Services. We may process your information as part of our efforts to keep our Services safe and
secure, including fraud monitoring and prevention.
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any
merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Business Partners. We may share your information with our business partners to offer you certain products, services,
or promotions.
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4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific
information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless
otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice,
unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize
such information, or, if this is not possible (for example, because your personal information has been stored in backup
archives), then we will securely store your personal information and isolate it from any further processing until deletion is
possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the
security of any personal information we process. However, despite our safeguards and efforts to secure your information, no
electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we
cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our
security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your
personal information, transmission of personal information to and from our Services is at your own risk. You should only
access the Services within a secure environment.
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that
you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the
Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the
account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we
may have collected from children under age 18, please contact us at info@tcwcapitalfinance.com.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have
the right to complain to your local data protection supervisory authority. You can find their contact details here:
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https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are available here:
https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express
and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can
withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?” below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law
allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than
consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional
communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the
details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed
from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages
that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing
purposes.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually
choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this
could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our
Services visit http://www.aboutads.info/choices/.
If you have questions or comments about your privacy rights, you may email us at info@tcwcapitalfinance.com.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or
setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored
and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been
finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically
communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the
future, we will inform you about that practice in a revised version of this privacy notice.
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal
information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California
residents to request and obtain from us, once a year and free of charge, information about categories of personal information
(if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which
we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to
make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to
request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us
using the contact information provided below and include the email address associated with your account and a statement
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that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that
the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a “resident” as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or
transitory purpose
All other individuals are defined as “non-residents.”
If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal
information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
Category Examples Collected
A. Identifiers
Contact details, such as real name, alias, postal address,
telephone or mobile contact number, unique personal identifier,
online identifier, Internet Protocol address, email address, and
account name
YES
B. Personal information categories listed
in the California Customer Records
statute
Name, contact information, education, employment,
employment history, and financial information YES
C. Protected classification characteristics
under California or federal law Gender and date of birth NO
D. Commercial information
Transaction information, purchase history, financial details, and
payment information NO
E. Biometric information Fingerprints and voiceprints NO
F. Internet or other similar network
activity
Browsing history, search history, online behavior, interest data,
and interactions with our and other websites, applications,
systems, and advertisements
NO
G. Geolocation data Device location NO
H. Audio, electronic, visual, thermal,
olfactory, or similar information
Images and audio, video or call recordings created in
connection with our business activities NO
I. Professional or employment-related
information
Business contact details in order to provide you our Services at
a business level or job title, work history, and professional
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qualifications if you apply for a job with us NO
J. Education Information Student records and directory information NO
K. Inferences drawn from other personal
information
Inferences drawn from any of the collected personal
information listed above to create a profile or summary about,
for example, an individual’s preferences and characteristics
NO
L. Sensitive Personal Information NO
We will use and retain the collected personal information as needed to provide the Services or for:
Category A – Indefinitely
Category B – Indefinitely
We may also collect other personal information outside of these categories through instances where you interact with us in
person, online, or by phone or mail in the context of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at info@tcwcapitalfinance.com, or by referring to the contact details at the bottom of this
document.
If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not
submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each
service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same
strict privacy protection obligations mandated by the CCPA.
We may use your personal information for our own business purposes, such as for undertaking internal research for
technological development and demonstration. This is not considered to be “selling” of your personal information.
TCW Capital Finance LLC has not disclosed, sold, or shared any personal information to third parties for a business or
commercial purpose in the preceding twelve (12) months. TCW Capital Finance LLC will not sell or share personal
information in the future belonging to website visitors, users, and other consumers.
Your rights with respect to your personal data
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Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect
your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to)
the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal
obligation, or any processing that may be required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell or share personal information to third parties;
the categories of personal information that we sold, shared, or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
the business or commercial purpose for collecting, selling, or sharing personal information; and
the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in
response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer’s sensitive personal information.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have
the information in our system. These verification efforts require us to ask you to provide information so that we can match it
with information you have previously provided us. For instance, depending on the type of request you submit, we may ask
you to provide certain information so that we can match the information you provide with the information we already have on
file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us.
We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the
extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we
cannot verify your identity from the information already maintained by us, we may request that you provide additional
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information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such
additionally provided information as soon as we finish verifying you.
Other privacy rights
You may object to the processing of your personal information.
You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing
of the information.
You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request
from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in
accordance with the CCPA.
You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving
an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from
the date of the request submission.
To exercise these rights, you can contact us by email at info@tcwcapitalfinance.com, or by referring to the contact details at
the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
11. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your
personal information.
Virginia CDPA Privacy Notice
Under the Virginia Consumer Data Protection Act (CDPA):
“Consumer” means a natural person who is a resident of the Commonwealth acting only in an individual or household
context. It does not include a natural person acting in a commercial or employment context.
“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person.
“Personal data” does not include de-identified data or publicly available information.
“Sale of personal data” means the exchange of personal data for monetary consideration.
If this definition “consumer” applies to you, we must adhere to certain rights and obligations regarding your personal data.
The information we collect, use, and disclose about you will vary depending on how you interact with TCW Capital Finance
LLC and our Services. To find out more, please visit the following links:
Personal data we collect
How we use your personal data
When and with whom we share your personal data
Your rights with respect to your personal data
Right to be informed whether or not we are processing your personal data
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Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data,
or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)
TCW Capital Finance LLC has not sold any personal data to third parties for business or commercial purposes. TCW Capital
Finance LLC will not sell personal data in the future belonging to website visitors, users, and other consumers.
Exercise your rights provided under the Virginia CDPA
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at info@tcwcapitalfinance.com, by visiting our data subject request form, or by referring to the
contact details at the bottom of this document.
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit
proof that they have been validly authorized to act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to verify you and your consumer’s request. If
you submit the request through an authorized agent, we may need to collect additional information to verify your identity
before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The
response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of
any such extension within the initial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to
appeal our decision, please email us at info@tcwcapitalfinance.com. Within sixty (60) days of receipt of an appeal, we will
inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons
for the decisions. If your appeal if denied, you may contact the Attorney General to submit a complaint.
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and
the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may
notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you
to review this privacy notice frequently to be informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
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If you have questions or comments about this notice, you may email us at info@tcwcapitalfinance.com or by post to:
TCW Capital Finance LLC
3343 Peachtree Rd NE Suite 145-1396
Atlanta, GA 30326
United States
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect
from you, change that information, or delete it. To request to review, update, or delete your personal information, please
submit a request form by clicking here.
This privacy policy was created using Termly’s Privacy Policy Generator.