Privacy Policy

Your privacy is important to us. This Privacy Policy applies to the online collection of non-public personal information via this Website and does not apply to information collected in any other way, including offline. These policies may be changed at any time.

What personal information is collected, who has access and how is that information used?

We may collect information about our users directly, from our web server logs and/or through “cookies”. “Cookies” are small text files that may be placed on your browser when you visit a web site. Cookies may be used to store and help track information or to help you navigate websites. The data identifies you as a unique user and facilitates your ongoing access to and use of this Website. Cookies also help Columbus Hill diagnose problems with its server. Most browsers are initially set up to accept cookies. However, if you prefer, you can set your browser to either notify you when you receive a cookie or to refuse to accept cookies. You should note however that certain sites may not function properly if you do not accept cookies.

We will not sell, rent or lease data to others, except our approved agents and contractors (who may use it on our behalf or in connection with their relationship with us) and except as necessary to service the account, to enforce the Terms of Use, to meet our obligations to content and technology providers or as required by law, in a matter of public safety or policy or as needed in connection with the transfer of our business assets or if we believe in good faith that sharing the data is necessary to protect our rights or property. Our affiliates are required to preserve the confidentiality of any personal information they may access.

Web server logs

When you visit our Website, we may track and store information electronically in web server logs, which are records of the activities on our sites. Examples of the information we may collect include:

  • Internet protocol address and Internet service provider
  • City, state and country from which our website is accessed
  • Kind of browser or computer accessing our website
  • The number of links clicked on within the Website
  • Date and time of access
  • Frequency of access
  • The web page from which a party arrives at our Website
  • Pages viewed on the Website
  • Certain searches/queries conducted via our website

Privacy Notice for California Users

Last updated:  June 2023

This notice contains disclosures required by the California Privacy Rights Act (“CPRA”). Terms defined in the CPRA have the same meaning when used in this notice. This notice is only relevant to California residents (“consumers” or “you”). Consumers with disabilities may access this notice by printing the pdf below which is compatible with character recognition software.

Click here to view the pdf

Information We Collect. In the past 12 months, we have collected and shared for a business purpose the following categories of personal information (“Personal Information”):

Category  Examples Collected Shared for Business Purpose
A. Identifiers A real name, alias, email address, postal address, Internet Protocol (IP) address, account name, Social Security number, driver’s license number, passport number, or other similar personal identifiers. NO NO
B. Other personal information categories, as listed in the California Customer Records Statute A signature, physical characteristics or description, telephone 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. NO NO
C. Protected classification characteristics under California or federal law Age (40 years or older), race, citizenship, marital status, sex, veteran or military status. NO NO
D. Commercial information Account activity, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO NO
E. Biometric information Fingerprints, faceprints, voiceprints, and iris or retina scans. NO NO
F. Internet or other similar network activity Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES YES
G. Geolocation data Physical location or movements. NO NO
H. Sensory data Audio, electronic, visual, thermal, olfactory, or similar information. NO NO
I. Professional or employment-related information Current or past job history or performance evaluations. NO NO
J. Non-public education information (per the Family Educational Rights and Privacy Act) Education records directly related to a student maintained by an educational institution or party acting on its behalf. NO NO
K. Inferences drawn from other personal information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO NO
L. Sensitive personal information A consumer’s SS, driver’s license, state ID card, or passport number; account log-in or debit/credit card number in combination with any access code, password, or account credentials; precise geolocation; racial/ethnic origin, religious/philosophical beliefs, or union membership; contents of mail, email, and text messages; genetic data; biometric information; PHI; or sex life or sexual orientation. NO NO

Personal Information does not include information that is publicly available, de-identified/ aggregated, or subject to HIPAA or GLBA.

We collect Personal Information as described above.

Purpose for Collection and Use of Personal Information.  We may collect or use Personal Information for one or more of the following purposes:

  • Providing you with information about our products and services;
  • Providing you with performance and other updates;
  • One or more of the following business purposes:
    • Performing services (for us or our service provider or contractor) such as account servicing, processing orders and payments, and analytics;
    • Auditing related to our interactions with you;
    • Legal compliance;
    • Detecting and protecting against security incidents, fraud, and illegal activity;
    • Debugging;
    • Internal research for technological improvement;
    • Internal operations;
    • Activities to maintain and improve our services; and
    • Short-term, transient use, such that the personal information is not disclosed to another third party and is not used to build a profile about you.


Sharing Personal Information.  We may disclose Personal Information to:

  • Service providers, including but not limited to: administrators, lenders, banks, brokers, auditors, law firms, consultants, placement agents, employment agencies, credit bureaus;
  • Affiliates;
  • Business partners;
  • Legal or government regulatory authorities as required by applicable law;
  • In connection with a potential business transfer; and
  • Third parties to whom you or your agents authorize us to disclose such information in connection with services we provide to you.

In the past 12 months, we have not sold Personal Information to third parties.

Length of Time. We will keep your Personal Information for as long as necessary to comply with our regulatory obligations.

Rights of California Consumers.  The CPRA provides a California consumer the following rights, subject to certain exceptions and limitations:

  • The right to request: (a) the categories and specific pieces of Personal Information we collect about you; (b) the categories of sources from which we collect your Personal Information; (c) our business or commercial purposes for collecting, selling or sharing your Personal Information; (d) the categories of Personal Information disclosed for a business purpose and the categories of persons to whom it was disclosed; (e) the categories of your Personal Information (if any) that we have either sold, shared, or disclosed.
  • For certain categories of Personal Information, the right to request a list of what we disclosed to third parties for their own direct marketing purposes in the past 12 months and the names and addresses of those third parties.
  • The right to request that we delete your Personal Information, subject to certain exceptions.
  • The right to opt out of our sale(s) (if any) of your Personal Information.
  • The right to request we correct any inaccurate Personal Information maintained about you.
  • The right to limit our use of your sensitive personal information to only use that is necessary to perform the services expected or provide the goods reasonably expected.
  • The right not to receive discriminatory treatment for exercising your CPRA rights.

You may submit requests relating to your exercise of CPRA rights to us via:

phone 844-615-8244



You may only make a verifiable request for access or data portability twice within a 12-month period. All verifiable requests must provide (1) enough information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative and (2) sufficient detail that allows us to properly evaluate and respond to it.

We endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.


If you have questions regarding this Notice, please contact us at