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Privacy Policy

3S DC LIFECYCLE MANAGEMENT, INC.

Effective Date: August 1, 2026
Last Updated: August 1, 2026
 
3S DC Lifecycle Management, Inc. (the “Company,” “we,” “us,” or “our”) respects the privacy of the individuals whose personal information we collect and process in connection with our equipment leasing, financing, servicing, underwriting, collections, vendor management, website operations, and related business activities. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information, and describes rights that may apply under certain laws.
This Privacy Policy applies to personal information collected online and offline, including through our websites, portals, applications, email communications, telephone calls, leasing and credit application materials, servicing interactions, marketing activities, vendor and broker relationships, and other business communications. In some cases, a separate privacy notice may apply, including a Gramm-Leach-Bliley Act (“GLBA”) privacy notice for covered consumer-facing activities, a notice at collection required by certain state laws, or a contractual notice delivered in a transaction-specific context.
 
Relationship to Parent Framework
The Company is part of the 3stepIT Group and recognizes the parent company’s group-wide privacy framework as the overarching privacy structure for the enterprise which can be found at Privacy policy | 3stepIT. The 3stepIT Privacy Policy and Data Privacy Instruction describes the parent-level roles of shareholders, the Board, the CEO, the Group Leadership Team, group risk management, group compliance, and related delegations and reporting structures.
 
This Privacy Policy supplements, and does not replace, the parent company’s privacy framework. To the extent the parent framework addresses enterprise privacy at the group level, this Policy establishes the U.S.-specific privacy governance, regulatory control, monitoring, complaints, remediation, and examination-readiness requirements applicable to the Company as a U.S. operating and licensed entity.
 
Where group policies or standards apply to the Company, the Company may rely on those policies to the extent they are consistent with U.S. law, applicable state law, licensing obligations, and the Company’s own approved procedures. Where U.S. law, regulator expectations, or license conditions impose more specific or more stringent requirements, this Policy and the Company’s U.S.-specific procedures shall govern with respect to the Company’s operations.
 
1. Scope and Important Limitations
This Privacy Policy is intended primarily for commercial transactions. Because commercial equipment leasing often involves businesses, business owners, guarantors, principals, beneficial owners, applicants, employees, website users, and service-provider personnel, the Company may collect information about both business entities and natural persons associated with those entities.
This Privacy Policy does not replace any separate GLBA privacy notice where the Company is acting as a “financial institution” with respect to consumer financial products or services. The GLBA requires covered financial institutions to explain their information-sharing practices to customers and to safeguard sensitive data, and the FTC’s Financial Privacy Rule requires covered institutions to provide certain notices and, in some circumstances, an opt-out before disclosing nonpublic personal information to nonaffiliated third parties outside applicable exceptions.
 
2. Categories of Personal Information Collected
Depending on the relationship with the Company and the nature of the transaction, the Company may collect the following categories of personal information:
 
  • Identifiers and contact data: name, business name, alias, postal address, email address, telephone number, online identifiers, IP address, login credentials, account usernames, and similar identifiers.
  • Commercial and transaction data: information about leased equipment, applications, quotes, invoices, payment histories, servicing history, collections activity, vendor and broker information, and transaction records.
  • Financial and underwriting data: bank account information, income information, financial statements, tax-related information, account balances, payment capacity information, credit history, credit scores or reports where permitted, and application decision data.
  • Government-issued and compliance data: driver’s license or state ID information, Social Security number or taxpayer identification number, beneficial ownership information, sanctions-screening information, fraud-prevention data, and other information used for know-your-customer, anti-fraud, or legal compliance purposes.
  • Professional and business role information: title, employer, business contact details, authority information, licensing information, and relationship to an applicant, lessee, guarantor, vendor, or service provider.
  • Internet or network activity: browser type, device information, operating system, referring URLs, interaction data, cookies, and usage information relating to our websites and portals.
  • Audio, visual, or similar information: call recordings, voicemail, video conference recordings, and security footage where permitted by law.
  • Inferences: inferences drawn from the information above to help evaluate equipment leasing eligibility, fraud risk, servicing needs, marketing preferences, and business relationship management.
The Company does not collect every category listed above in every situation, and the specific data elements collected depend on the type of transaction, service, or interaction involved.
 
3. Sources of Personal Information
The Company may collect personal information from:
  • You or your business directly, including through applications, forms, correspondence, phone calls, website submissions, account registration, and servicing interactions.
  • Equipment vendors, brokers, referral partners, and other transaction participants.
  • Credit bureaus, consumer reporting agencies, commercial reporting agencies, background screening providers, identity verification providers, and fraud-prevention vendors, where permitted by law.
  • Public records, government agencies, corporate registries, lien-search providers, and similar sources.
  • Cookies, analytics providers, website logs, and similar technologies when you use our online services.
  • Affiliates, service providers, and counterparties involved in funding, servicing, collections, compliance, or portfolio administration.
 
4. Purposes for Collection and Use
The Company may collect, use, and otherwise process personal information for the following business and commercial purposes:
  • To evaluate applications, underwrite leases, verify identity, assess creditworthiness, and make leasing or financing decisions.
  • To document, fund, service, administer, and enforce leases and related agreements.
  • To process payments, manage accounts, respond to inquiries, provide customer support, and maintain business records.
  • To detect, prevent, investigate, and respond to fraud, unauthorized transactions, identity theft, security incidents, and other unlawful activity.
  • To comply with legal and regulatory obligations, including recordkeeping, subpoena response, litigation management, examinations, audits, sanctions screening, and governmental requests.
  • To maintain, secure, and improve our systems, websites, portals, products, and services.
  • To communicate about products, services, events, and developments that may be relevant to current or prospective business relationships, subject to applicable law.
  • To perform internal analytics, portfolio management, reporting, forecasting, and business planning.
Where required by applicable law, the Company will provide additional notices regarding sensitive personal information, cookies, automated decision-making, or other processing activities.
 
5. Disclosure of Personal Information
The Company may disclose personal information to the following categories of recipients, subject to applicable law and contractual or legal restrictions:
  • Affiliates and related entities for internal administration, servicing, risk management, compliance, and other lawful business purposes.
  • Equipment vendors, brokers, originators, referral sources, assignees, purchasers, warehouse providers, lenders, and other financing or transaction counterparties involved in a lease or financing relationship.
  • Service providers and contractors that perform services on our behalf, such as payment processors, cloud providers, software providers, customer relationship management vendors, document custodians, auditors, collection agencies, call centers, security vendors, analytics providers, and professional advisers.
  • Credit bureaus, commercial reporting agencies, fraud-prevention providers, identity verification providers, and similar vendors.
  • Government agencies, regulators, courts, law enforcement, and parties to litigation or investigations where required or permitted by law.
  • Successors in interest and transaction counterparties involved in an actual or proposed merger, acquisition, financing, sale of assets, securitization, or portfolio transfer.
If the Company is subject to GLBA for a particular relationship, disclosure of nonpublic personal information may be limited by the FTC’s Financial Privacy Rule, including the requirement to provide privacy notices and, when no exception applies, an opportunity to opt out before sharing with certain nonaffiliated third parties.
The Company does not sell personal information for money. However, the Company may use cookies, pixels, analytics tools, and similar technologies in ways that may constitute “sharing” or a “sale” of personal information under applicable law.
 
6. Cookies and Similar Technologies
Our websites and portals may use cookies, pixels, tags, session replay tools, log files, and similar technologies to operate online services, authenticate users, remember preferences, analyze traffic, detect security events, and improve site functionality. Some of these practices may be subject to state-law notice, consent, opt-out, or preference-signal requirements depending on the jurisdictions involved and the nature of the technology deployed.
 
7. Data Retention
The Company retains personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to evaluate and service transactions, maintain records, comply with legal obligations, resolve disputes, enforce agreements, and protect the Company’s rights and systems. Retention periods may vary based on transaction type, record category, legal hold obligations, regulatory expectations, limitation periods, and operational needs.
When personal information is no longer required, the Company will take reasonable steps to delete, de-identify, or securely dispose of the information in accordance with applicable law and records-management practices.
 
8. Data Security
The Company maintains administrative, technical, and physical safeguards designed to protect personal information appropriate to the size and complexity of the business, the nature and scope of its activities, and the sensitivity of the information involved. The FTC Safeguards Rule requires covered financial institutions to develop, implement, and maintain a written information security program designed to protect customer information.
These safeguards may include access controls, encryption, multifactor authentication, risk assessments, vendor oversight, incident response procedures, secure disposal practices, employee training, and monitoring controls. No method of transmission over the internet or method of storage is completely secure, so the Company cannot guarantee absolute security.
 
9. State Privacy Rights
Residents of certain states may have privacy rights regarding personal information, which can include the right to know, access, correct, delete, obtain a copy of personal information, or opt out of certain disclosures, sales, sharing, profiling, or targeted advertising, subject to exemptions and limitations. State laws may also require a notice at collection, a description of categories collected and disclosed, a description of retention criteria, and instructions for exercising rights and appealing denied requests.
For example, the California Consumer Privacy Act requires covered businesses to provide consumers with a notice at collection that identifies the categories of personal information collected and the purposes for which those categories are used, and that notice must link to the business’s privacy policy.
Where required by applicable state privacy laws, the Company may provide state‑specific privacy notices, rights information, or addenda, which should be read together with this Privacy Policy. The Company’s notice at collection may be delivered through online forms, portal registration pages, broker or vendor intake materials, or other channels appropriate to the context in which personal information is collected.
 
Exercising Privacy Rights
To submit a privacy request where state law provides that right, contact the Company using the information below:
The Company may need to verify the requester’s identity and authority before responding. Authorized agents may submit requests on behalf of individuals where permitted by law and subject to verification requirements.
 
Appeals
Where required by applicable law, individuals may appeal a denial of a privacy request by following the instructions provided in the response to the request.
 
10. GLBA and Separate Financial Privacy Notices
If the Company offers or services consumer financial products or services, it may provide an initial privacy notice, annual privacy notice, and other disclosures required by GLBA and implementing regulations. Those notices may address categories of nonpublic personal information collected, categories of information disclosed, categories of affiliates and nonaffiliated third parties receiving the information, and any applicable opt-out rights.
 
11. Children’s Privacy
The Company’s services are intended for businesses and adults, not for children under 13, and the Company does not knowingly collect personal information directly from children under 13 through its commercial leasing services. If the Company learns it has collected such information without appropriate authorization, it will take reasonable steps to delete it.
 
12. Cross-Border Data Transfers
If the Company transfers personal information across state or national borders, it may do so for servicing, hosting, support, security, analytics, or other legitimate business purposes, subject to appropriate safeguards and contractual protections where required.
 
13. Third-Party Websites and Services
Our websites and communications may contain links to third-party websites, plug-ins, portals, or services that are not controlled by the Company. The Company is not responsible for the privacy, security, or content practices of those third parties, and individuals should review the applicable privacy notices of those third parties before providing information.
 
14. Changes to this Privacy Policy
The Company may update this Privacy Policy from time to time to reflect changes in law, regulation, technology, business practices, or operational requirements. When required by law, the Company will provide additional notice or obtain consent regarding material changes.
 
15. Contact Information
For questions about this Privacy Policy or the Company’s privacy practices, contact:
3S DC Lifecycle Management, Inc.
Attn: Privacy Office / Compliance Department
30 Technology Dr.
Warren, NJ 07059
Phone: 844-671-5630
 
16. Special Section for California Residents
This section applies to California residents to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), applies to the Company’s collection, use, disclosure, and other processing of personal information. Certain personal information may be exempt from the CCPA, including information subject to the Gramm-Leach-Bliley Act and implementing regulations, but those exemptions may not apply to all categories of information or all processing activities. The Company will not discriminate against California residents for exercising rights under the CCPA, except to the extent differential treatment is expressly permitted by law (for example, in connection with bona fide loyalty or rewards programs).
 
Personal Information Collected
During the preceding 12 months, the Company may have collected the following categories of personal information about California residents: identifiers; personal information described in California Civil Code section 1798.80(e); protected classification characteristics under California or federal law; commercial information; internet or other electronic network activity information; geolocation data; audio, electronic, visual, or similar information; professional or employment-related information; education information; sensitive personal information; and inferences drawn from personal information to create a profile reflecting preferences, characteristics, behavior, attitudes, intelligence, abilities, or aptitudes. The precise categories collected depend on the nature of the individual’s relationship with the Company and the services or transactions involved.
 
Sources of Personal Information
The Company may collect personal information directly from California residents, from their businesses or representatives, from equipment vendors, brokers, referral partners, service providers, analytics providers, advertising partners, credit and fraud-prevention vendors, public records, and other third parties involved in leasing, servicing, compliance, security, or website operations.
 
Purposes for Collection, Use, and Disclosure
The Company may collect, use, disclose, and otherwise process personal information for the business and commercial purposes described in this Privacy Policy, including underwriting, application review, identity verification, fraud prevention, account servicing, payment processing, collections, customer support, website functionality, analytics, marketing, legal compliance, record retention, regulatory response, and protection of the Company’s systems, rights, and property.
 
Categories of Third Parties to Whom Personal Information Is Disclosed
The Company may disclose personal information to affiliates, service providers, contractors, equipment vendors, brokers, funding sources, assignees, collection agencies, fraud-prevention providers, analytics providers, professional advisers, regulators, governmental authorities, courts, and counterparties involved in actual or proposed corporate transactions, where permitted by law.
 
Retention
The Company retains personal information for no longer than reasonably necessary and proportionate for the purposes described in this Privacy Policy, taking into account the nature and sensitivity of the information, the purposes for which it is collected and used, legal and regulatory retention obligations, limitation periods, dispute resolution needs, security requirements, and operational necessity. In some cases, the Company may retain information longer where required or permitted by law.
 
California Privacy Rights
Subject to applicable exceptions and verification requirements, California residents may have the right to:
  • Know the categories of personal information the Company has collected about them, the categories of sources, the business or commercial purposes for collecting, selling, or sharing personal information, the categories of third parties to whom personal information is disclosed, and the specific pieces of personal information the Company has collected about them.
  • Request deletion of personal information collected from them.
  • Request correction of inaccurate personal information maintained by the Company.
  • Opt out of the sale or sharing of personal information.
  • Limit the use and disclosure of sensitive personal information, where the Company uses or discloses sensitive personal information for purposes not subject to an exception under California law.
  • Receive equal service and price and not be discriminated or retaliated against for exercising rights provided by the CCPA.
 
Submitting Requests
California residents may submit requests by using the methods listed below:
The Company will verify requests using information appropriate to the sensitivity of the request and the information sought. Authorized agents may submit requests on behalf of California residents where permitted by law, subject to the Company’s verification of the agent’s authority and, where appropriate, the identity of the resident.
 
Sale, Sharing, and Sensitive Personal Information
The Company does not sell personal information for monetary consideration. However, the Company may use cookies, pixels, analytics tools, and similar technologies in ways that may constitute “sharing” or a “sale” of personal information under California law. California residents may opt out by filling in this form on this page https://www.3stepit.com/california-your-privacy-choices  or by enabling a legally recognized opt-out preference signal, where required. Where required by California law, the Company will treat a valid opt‑out preference signal received through its online services as a request to opt out of the sale or sharing of personal information associated with the browser or device, and, where feasible, the consumer.
The Company uses and discloses sensitive personal information only as reasonably necessary to perform services, provide requested goods or services, prevent fraud, ensure security, verify information, comply with law, and for other purposes permitted by California law.
 
Notice at Collection
At or before the point of collection, the Company provides or makes available a notice describing the categories of personal information collected, the purposes for which they are used, whether the information is sold or shared, retention information, and a link to this Privacy Policy, as required by California law.
 
Last Updated
This California section was last updated on August 1, 2026.