Breakthrough Broker (“our,” “us,” or “we”) respects and is committed to protecting your privacy. This California Privacy Notice explains how we collect, use, and disclose Personal Information, when and to whom we disclose such information, and the rights you, as a California resident (“Consumer”), have regarding your Personal Information (“California Privacy Rights”).

Collection of Categories of Personal Information:

In the preceding 12 months, Breakthrough Broker has collected, and will continue to collect, the following categories of Personal Information from you:

• Identifiers such as name, address, telephone number, IP address, email address, account name, social security number, driver’s license number, state identification card, financial information, date of birth, or other similar identifiers;
• Characteristics of protected classifications under California or Federal law;
• Commercial information, including records of personal property, products or services purchased, or other purchasing or consuming histories;
• Internet or other electronic network activity information including, but not limited to browsing history, search history, and information regarding a Consumer’s interaction with an Internet website or advertisement;
• Geolocation data;
• Professional or employment information;
• Education Information.

This Personal Information is collected from the following sources:

• You or your agent on applications or other forms or from your transactions or interactions (including use of websites and mobile applications and engagement with advertisements);
• Third party advertising vendors, data analytics providers, internet service providers, and social networks;
• Breakthrough Broker, our affiliates, or others you have transacted with;
• Consumer reporting agencies and/or governmental entities, either directly from these entities or through others.

This Personal Information is collected for the following business purposes:

• To provide products and services to you or in connection with a transaction involving you;
• To advertise to you;
• To perform a contract between Breakthrough Broker and the Consumer;
• To improve our products and services;
• To comply with legal obligations;
• To protect against fraudulent or illegal activity;
• To communicate with you about Breakthrough Broker or our affiliates;
• To maintain an account with Breakthrough Broker or our affiliates;
• To provide support, personalize, and develop our websites, products, and services;
• As described to you when collecting your personal information or as otherwise permitted by the California Consumer Privacy Act.

Disclosures of Personal Information for a business purpose:

In the preceding 12 months, Breakthrough Broker has disclosed, and will continue to disclose, the categories of Personal Information listed above for a business purpose. We may disclose Personal Information for a business purpose to the following categories of third parties:

• Our affiliates and other Breakthrough Broker subsidiaries;
• Non-affiliated third parties, as directed or permitted by you;
• Businesses in connection with the sale or other disposition of all or part of the Breakthrough Broker business and/or assets;
• Service Providers and non-affiliated third parties such as internet service providers, data analytics providers, and social networks;
• Law enforcement or authorities in connection with an investigation, or in response to a subpoena or court order.

Sale and Sharing of Personal Information:

We may also share your Personal Information by selling it to third parties, subject to your right to opt-out of those sales. In the preceding 12 months, as the terms are defined by the California Consumer Privacy Act (CCPA), as amended, Breakthrough Broker has “sold” or “shared” the following categories of information:

• Internet or other electronic network activity information

Breakthrough Broker has “sold” the above categories of information collected from your activity on our websites to non-affiliated third parties such as internet service providers, data analytics providers, and social networks, to enable us to provide you with advertisements about our products and services on our websites and on third party websites. These “sales” may also take the form of “sharing,” as defined under California law, when those third parties engage in cross-context behavioral advertising on our behalf. To opt-out of Personal Information “sales” or “sharing” visit Support@BreakthroughBroker.com. Breakthrough Broker does not “sell” or “share” Sensitive Personal Information. Our Personal Information sales or sharing does not include information about individuals we know are under age 16.

Retention Periods:

Due to the breadth and variety of data collected by Breakthrough Broker, it is not possible for us to provide you with a comprehensive list of timeframes during which we retain each category of Personal Information. Breakthrough Broker retains categories of information as reasonably necessary to satisfy the purpose for which we collect the information. This time period varies depending on the purpose for which we collected the information, the nature and frequency of our interactions and relationship with you, whether we have a legal basis to continue retaining the information, industry practices, the value and sensitivity of the information, and state and federal recordkeeping requirements.

Personal Information of minors:

Breakthrough Broker does not knowingly collect the Personal Information of minors.

Sensitive Personal Information:

Consumers have the right to limit the use or disclosure of their “Sensitive Personal Information” to just actions necessary to perform specific purposes listed in the CCPA, as amended. Sensitive Personal Information includes government identifiers (social security, driver’s license number or state ID, and passport number), precise geolocation, racial or ethnic origin, and other categories defined in California law. Breakthrough Broker does not use or disclose Sensitive Personal Information for any purposes other than those specified in the CCPA, as amended.

Right to know:

Consumers have a right to know about Personal Information collected, used, disclosed, shared, or sold, including the categories of such Personal Information, as well as the purpose for such collection, use, disclosure, sharing, or selling, categories of third parties to whom Personal Information is disclosed, shared or sold, and the specific pieces of Personal Information collected about the consumer. Consumers have the right to request Breakthrough Broker disclose what Personal Information it collected, used, and disclosed in the past 12 months, or since January 1, 2022.

Right to request deletion:

Consumers have a right to request the deletion of their personal information.

Right to Correct:

Consumers have the right to correct inaccurate Personal Information.

Right to non-discrimination:

Consumers have a right not to be discriminated against for exercising their consumer privacy rights. We will not discriminate against Consumers for exercising any of their California Privacy Rights.

Privacy Requests

To exercise any of your California Privacy Rights, or if acting an authorized agent on behalf of another individual, please visit California Privacy Request, call us Toll Free at 888-413-1748, or write to the address at the end of this notice.

Upon making a California Privacy Request, Breakthrough Broker will verify the consumer’s identity by requiring an account, loan, escrow number, or other identifying information from the consumer.

The above-rights are subject to any applicable rights and obligations including both federal and California exemptions rendering Breakthrough Broker, or Personal Information collected by Breakthrough Broker, exempt from certain CCPA requirements.

A Consumer may use an Authorized Agent to submit any CCPA request. Authorized agents’ requests will be processed like any other CCPA request, but Breakthrough Broker will also require the Consumer provide the agent written permission to make the request and verify his or her identity with Breakthrough Broker.

California Privacy Notice – Effective Date:

Contact for more information:

For questions or concerns about Breakthrough Broker’s California Privacy Notice and privacy practices, or to exercise any of your California Privacy Rights, please follow the link “California Privacy,” call Toll Free 888-413-1748, or by mail to: