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Privacy Policy for California Residents

Privacy Policy for California Residents

This privacy policy is provided pursuant to the California Consumer Privacy Act (the “CCPA”) and applies to California residents (“consumers”). This privacy policy supplements the information provided in our Privacy Policy. Any terms used and defined by the CCPA have the same definitions and meaning herein.

The Types of Personal Information We Collect

Please be aware that during the course of our business, we may collect and use personal information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer, device, or household (“personal information”). The types of information we could collect varies on each individual consumer and the nature of our relationship with them. However, in the past twelve (12) months, we may have collected the following types of personal information about consumers:

• Identifiers, such as name, alias, postal address, email address, account name and number, insurance policy information, and government-issued identifiers (e.g., Social Security number, driver’s license number, etc.);
• Personal information, including but not limited to information defined in the California safeguards law, such as contact information and financial information;
• Characteristics of protected classifications under California or federal law, such as sex and marital status;
• Commercial information, such as records of personal property, transaction information and purchase history;
• Biometric information;
• Internet or network activity information, such as browsing history and interactions with our website;
• Geolocation data, such as device location and Internet Protocol (IP) location;
• Audio, electronic, visual and similar information, such as call recordings;
• Professional or employment-related information;
• Education information; and
• Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.


Methods for Collecting Personal Information

Most of the personal information we have about a consumer is given to us by our clients when they retain our services. In addition, we collect personal information directly from you, such as through telephone conversations, written correspondence sent via mail, email or fax, viewing your public social media/network pages, or other information available publicly online. We may also collect information from public records, from our service providers (e.g. letter vendors, skip tracing vendors, payment processing vendors, etc.), directly from a third party (e.g. third parties contacted pursuant to the Fair Debt Collection Practices Act, such as a friend, neighbor, relative and/or employer), directly from a third party with your consent (e.g. your attorney or other authorized representative), and/or activity from our website and your usage of our site.

Disclosure or Sale of Personal Information

We have not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months, nor have we sold the personal information of minors under the age of sixteen (16) in the preceding twelve (12) months.

In the past twelve (12) months, we may have disclosed personal information about consumers for business purposes and/or to comply with legal requirements. Within the course of our business, it may become necessary to disclose personal information to third parties. Such disclosures are made to: (a) third party service providers we use to assist in the delivery of our services, examples include our letter vendors and entities that assist with our technology and infrastructure needs; (b) third parties necessary to run our business, such as banking services, insurers, legal professionals, tax professionals, etc.; (c) third parties approved by you, including third-party payment service providers; (d) credit reporting agencies, if applicable; (e) government agencies as required by law and regulations; and (f) pursuant to our Terms and Conditions and Privacy Policy.

The types of information we disclose to third parties include, but may not be limited to: personal identifiers, financial information, employment information, and commercial information. We may also disclose internet or other electronic network activity to customize your experience on our webpage based on your apparent interests or needs.

Your Rights under the CCPA

Right to Know

Pursuant to the CCPA, you have the right to request that we disclose to you certain information about our collection and use of your personal information over the past twelve (12) months. Upon receipt and confirmation of your verified consumer request, we will provide the following information:
• The categories of personal information we collected about you;
• The categories of sources for the personal information we collected about you;
• Our business or commercial purpose for collecting that personal information;
• The categories of third parties with whom we share your personal information; and
• The business or commercial purpose for which we disclosed the category of personal information.


Right to Know the Disclosure of Personal Information Sold or Used for a Business Purpose

In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:
• The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
• The categories of personal information that we disclosed about you for a business purpose.
Please note that we do not engage in the sale of personal information and we have not sold personal information in the preceding twelve (12) months.


Right to Request Deletion

You have the right to request that we delete any personal information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your request to delete your personal information if retaining the information is necessary for us or our service providers to: (1) Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’ ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer; (2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; (3) Debug to identify and repair errors that impair existing intended functionality; (4) Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law; (5) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code; (6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the business’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent; (7) Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business; (8) Comply with a legal obligation; or (9) Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

Protection from Discrimination

We will not discriminate against you in any way for exercising the rights provided to you by the CCPA.

How to Exercise Your Rights under the CCPA

To exercise the rights described herein, please submit a verifiable consumer request to us by either:

Contacting us at:

1-800-973-0600
Or

Submitting your request through our online inquiry form

Please note that you may only make a verifiable consumer request twice (2) within a twelve (12) month period. In addition, only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
Before we can respond to your request pursuant to the CCPA, we must confirm your identity and that you are authorized to receive the personal information requested. The amount and type of information we need from you to confirm your identity varies depending on the type of request being made and the type of information you are requesting.
If we cannot verify that the person making the request is the person about whom we collected information or is not an authorized individual to act on that person’s behalf, we are not obligated to respond to your request or provide the personal information.
We will only use the personal information provided in a request to confirm the individual’s identity or authority to make the request.
We will respond to a verifiable consumer request within forty-five (45) days of its receipt. If we need additional time to respond (up to ninety (90) days), we will inform you of the extension period and the reason for the extension in writing. The disclosures we provide, if any, will cover the twelve (12) month period preceding receipt of the verifiable consumer’s request. If applicable, the response will also provide the reason(s) we cannot comply with a request.

Changes to this Policy

We reserve the right to amend this privacy policy at our discretion and at any time. If we make changes to this privacy policy, we will post the policy on our website and update the “Last Updated” date accordingly and/or notify you by other means consistent with applicable law.

Last updated January 2020

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