Privacy Policy

This Privacy Policy describes how Simple Management Group, Inc. and its affiliates and subsidiaries CashWiz, La Familia Pawn & Jewelry, and Simple Pawn, including the associated websites and mobile applications (collectively, "Company," "we," "us," or "our") collects, uses, shares, and protects personal information. This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions.

You can jump to particular topics by going to the headings below:

• Information We Collect
• How We Use Information
• How We Share Information
• Your Choices
• How We Protect and Retain Information
• Transmission Of Information To Other Countries
• Third-Party Applications/Websites
• Changes To This Privacy Policy
• Children
• Contact Information
• Additional Information For California Residents

Information We Collect

We collect information about you in a variety of ways depending on how you interact with us and our websites, mobile applications, products, and services, including:

• Directly from you when you provide it to us, such as when you register for an account, sign up to receive communications from us, place an order/make a purchase, request in-store services such as jewelry cleanings, pawn/sell/consign an item, or contact us by phone, email, or otherwise.
• Automatically through the use of cookies, server logs, and other similar technologies when you interact with our websites, mobile applications, advertisements, and emails.
• From other sources, including, for example, our affiliates, business partners, service providers, online social media networks, and other third parties, or from publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check. Additionally, if you purchase or trade a government-regulated product, we may conduct a background check as required by law.

The following provides examples of the type of information that we collect in a variety of contexts and how we use that information.

Context	Types of Personal Information	Primary Purpose for Collection and Use of Personal Information
Account Registration	We collect your name and contact information when you create an account. We also collect information relating to the actions that you perform while logged into your account.	We use this information to provide account related functionalities to our users. Accounts can be used to save your preferences and transaction history, and track rewards and redemptions.
Your Use of Our Website	We use technology to monitor how you interact with our websites. This may include which links you click on, or information that you type into our online forms. Some of these technologies may use "cookies." Cookies are small pieces of information that a website sends to a computer's hard drive while a website is viewed. Other types of data we track include your IP address, the website that referred you to our website, and data about the device you use to visit our website.	We use this information to make our website operate efficiently. We also use it to understand how you interact with our websites to improve them and understand your preferences. Finally, we use this information to help detect and prevent fraud.
Demographic Information	We collect personal information, such as your age or location.	We use this information to understand our users and providing tailored services.
Distance Information	When you use one of our apps we may collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location and your distance from a store that sells our products.	We use this information to understand our users and providing tailored services. In some contexts our use is also based upon your consent to provide us with geo location information.
Email Interconnectivity	If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.	We use this information to understand how you interact with our communications to you.
Employment	If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment.	We use information about current employees to perform our obligations to employees. In some contexts, we are also required by law to collect information about employees or applicants. We also use this information to have efficient staffing and work force operations.
Feedback/Support	If you provide us feedback or contact us for support we will collect your name and email address, as well as any other content that you send to us, in order to reply.	We use this information to receive, and act upon, your feedback or issues.
Government- Regulated Purchases and Trades	We may collect personal information on behalf of government entities to fulfill legal requirements related to government-regulated purchases. Use of that information is dictated by those agencies and applicable legal requirements.	We use this information to comply with laws and regulations pertaining to government-regulated sales.
Mailing List	When you sign up for one of our mailing lists we collect your email address.	We use this information to share information about our products and services with individuals that consent to receive such information.
Mobile Devices and Applications	We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website or when visiting one of our stores. Our mobile app may also collect other personal information such as identifiers, contact information, usage data, information you provide using in-app communication methods, and other diagnostic data.	We use this information to identify unique visitors, and to understand how users interact with us on their mobile devices. We also use this information to provide and improve the functionality of our mobile app.
Pawns, Sales, Purchases, and Other Services	We collect your name, billing address, shipping address, email address, phone number, and credit or debit card information when you pawn or consign an item with us, sell an item to us, purchase an item from us, or otherwise use our in-store services.	We use your information to perform our contract to provide you with products or services.
Promotions	We collect information that you provide as part of either one of our promotions.	We use this information to fulfill our promotions.
Surveys	When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third party service provider, the third party's privacy policy applies to the collection, use, and disclosure of your information.	We use this information to understand your opinions, and collect information relevant to our organization.
Loyalty Program	When you participate in our Loyalty Program, we collect information such as contact information.	We use this information to operate the loyalty program. In some contexts we are also required by law to collect information about those that enter into our sweepstakes, and we use this information in complying with those laws.
Website interactions	We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.	We use this information to understand how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also use this information to detect and prevent fraud.

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How We Use Information

In addition to the purposes and uses described above, we use information in the following ways:

• To identify you when you visit our websites, mobile apps, or our stores.
• To provide products and services or to process returns.
• To improve our services and product offerings.
• To streamline the checkout process.
• To conduct analytics.
• To communicate with you, such as to respond to and/or follow-up on your requests, inquiries, issues, or feedback.
• To send marketing and promotional materials including information relating to our products, services, sales, or promotions, or those of our business partners.
• To detect and protect against malicious, deceptive, fraudulent, or illegal activity, including violation of our policies and terms and conditions, security incidents, and harm to the rights, property, or safety of our company and our users, employees, or others.
• To debug, identify and repair errors that impair existing intended functionality of our websites, mobile apps, and services.
• To comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
• For internal administrative purposes, as well as to manage our relationships.
• For such other purposes as you may consent (from time to time).

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you complete a purchase, we may collect your information to perform our contract with you, but we also maintain your information after your transaction is complete so that we can quickly and easily respond to any questions about your purchase. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or in the course of conducting our business.

To the extent we maintain and use personal information in a deidentified form, we will not attempt to reidentify the information, except for the purpose of determining whether our deidentification processes satisfy our legal obligations.

How We Share Information

In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information in the following situations:

• Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
• Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.
• Service Providers. We may share your information with service providers. Among other things service providers may help us to administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.
• Other Disclosures with Your Consent. We may disclose your information to other third parties when we have your consent or direction to do so.

Notice of Collection. The table below describes the categories of personal information we collect, disclose for a business purpose, "sell" and/or "share" (as those terms are defined by applicable law). Please note, in addition to the recipients identified below, we may disclose any of the categories of personal information we collect with government entities, as may be needed to comply with law or prevent illegal activity. We do not "sell" your personal information for money. As discussed elsewhere in the Privacy Policy, we use cookies and similar tracking technologies for purposes of targeted advertising. For more information, please see the Cookies and Similar Tracking Technologies section of the Privacy Policy. For details regarding how we use personal information, please see the Information We Collect section of the Privacy Policy. For information regarding how long we retain personal information, please refer to the How We Protect and Retain Information section of the Privacy Policy.

Category of Personal Information	Disclosures for a Business Purpose
Identifiers - this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.	Affiliates or subsidiaries Business partners Data analytics providers Data brokers Internet service providers Joint marketing partners Operating systems and platforms Other Service Providers Payment processors and financial institutions Professional services organizations, this may include auditors and law firms Social networks
Government Issued Identification - this may include social security number, driver's license number, or state issued identification number, passport number.	Affiliates or subsidiaries Business partners Operating systems and platforms Other Service Providers Payment processors and financial institutions Professional services organizations, this may include auditors and law firms Government agencies, where required by law
Financial Information - this may include bank account number, credit card number, debit card number, and other financial information.	Affiliates or subsidiaries Business partners Operating systems and platforms Other Service Providers Payment processors and financial institutions
Characteristics of protected classifications - this may include age.	Affiliates or subsidiaries Business partners Operating systems and platforms Other Service Providers Payment processors and financial institutions Professional services organizations, this may include auditors and law firms
Commercial information - this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Affiliates or subsidiaries Business partners Internet service providers Joint marketing partners Operating systems and platforms Other Service Providers Payment processors and financial institutions Professional services organizations, this may include auditors and law firms
Internet or other electronic network activity information - this may include browsing history, search history, and information regarding an individual's interaction with an internet website, application, or advertisement.	Affiliates or subsidiaries Business partners Data analytics providers Data brokers Internet service providers Joint marketing partners Operating systems and platforms Other Service Providers
Geolocation data	Affiliates or subsidiaries Business partners Internet service providers Operating systems and platforms Other Service Providers
Professional or employment-related information	Affiliates or subsidiaries Business partners Operating systems and platforms Other Service Providers Payment processors and financial institutions Professional services organizations, this may include auditors and law firms
Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) - this may include signature, physical characteristics, or description, insurance policy number.	Affiliates or subsidiaries Business partners Operating systems and platforms Other Service Providers Professional services organizations, this may include auditors and law firms

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Your Choices

Some jurisdictions give you a right to make the following choices regarding your personal information:

• Access To Your Personal Information. You may request access to your personal information or confirmation that we have information about you. In certain limited circumstances, you may also request to receive access to your data in a portable, machine-readable format.
• Changes To Your Personal Information. We rely on you to update and correct your personal information. Most of our websites and our mobile applications allow you to modify or delete your account profile. If our website or mobile application does not permit you to update or correct certain information, you can contact us at the address described below in order to request that your information by modified. You may ask us to correct information that is inaccurate or incomplete. Note that we may keep historical information in our backup files as permitted by law.
• Deletion Of Your Personal Information. You may request that we delete your personal information. If required by law, we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another business purposes. Visit the Account Deletion Policy to learn how to delete your account.
• Objection to or Restriction of Certain Processing. In certain circumstances, you may object to the processing of your personal information, or request that we restrict processing of your personal information, by following the instructions described below.
• Online Tracking. We do not currently recognize the "Do Not Track" signal.
• Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.
• Promotional Text Messages. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying "STOP.
• Revocation Of Consent. Where we process your personal information based upon consent, you may revoke consent. Please note, if you revoke your consent for the processing of personal information then we may no longer be able to provide you services.

Please note, not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity. We will not discriminate against individuals who exercise their privacy rights under applicable law.

Submitting Requests

You may exercise the rights described above by contacting us as indicated in the "Contact Information" section below. If you disagree with our denial of a request, you may appeal our decision by contacting us at info@smg.inc with the subject line "Appeal."

Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, the last item you purchased from us, or the date of your last purchase from us. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of a completed Authorized Agent Designation Form indicating that you are able to act on another person's behalf.

How We Protect and Retain Information

No method of transmission over the internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our websites and mobile applications permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.

We retain your personal information for only as long as necessary to fulfil the purposes outlined in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements.

Transmission Of Information To Other Countries

As a multi-national company, we transmit information between and among our affiliates. As a result, your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. By submitting your personal information to us you agree to the transfer, storage, and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.

Third-Party Applications/Websites

For your convenience, we may provide links to websites and other third-party content or services that we do not own or operate. The websites and third-party content to which we link may have separate privacy notices or policies. Please note, we have no control over the privacy practices websites, or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about such third party's privacy practices.

Changes To This Privacy Policy

We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an "effective" and "last updated" date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified. If we make a material change to our privacy notice, we will attempt to notify you through email or through a website pop-up.

Children

Our websites and online services are not intended for children under the age of 13 and we do not knowingly collect personal information from children under age 16, without parental consent. Children under the age of 13 should not provide their personal information to us.

Contact Information

If you have any questions, comments, or complaints concerning our privacy practices, or if you need to access this Privacy Policy in an alternative format due to having a disability, please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.

info@smg.inc
2600 Lake Lucien Dr, Suite 116
Maitland, FL 32751

Additional Information for California Residents

California law requires us to disclose the following additional information related to our privacy practices. If you are a California resident, the following privacy disclosures apply to you in addition to the rest of the Privacy Policy.

• California Shine the Light. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the information in the Contact Information section above.
• California Notice of Financial Incentive. We offer programs that provide certain perks, such as rewards, discounts, and exclusive offers (the "Loyalty Programs"). When you sign up for a Loyalty Program, we will ask you to provide your name, email address, telephone number, and in some cases loan information or identification numbers. Under California law, our Loyalty Programs might be interpreted as "financial incentive" programs as they involve the collection of personal information. We do not assign a monetary value to the information we collect. Based on our reasonable estimate, the value of your personal information to us is related to the value of the free or discounted products or services that you obtain when you redeem your rewards. This value is based on the expense related to offering those free or discounted products or services. You may withdraw from participating in the Loyalty Programs at any time by contacting us at the address described in the program terms and conditions. Visit the Rewards Program page to view full program rules, including how to join.
• California Sensitive Information Disclosure. We collect the following categories of sensitive personal information (as defined under California law): precise geolocation data, biometric data, racial or ethnic origin, payment information, and government identifiers such as a driver's license. This information is collected in order to process transactions, comply with laws, manage our business, or provide you with services. Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121. We do not "sell" or "share" sensitive personal information for purposes of cross-context behavioral advertising.

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Effective and Last Updated as of: August 20, 2024