Collection Bureau of America Ltd.
INTRODUCTION AND CONSENT
WHAT INFORMATION DOES THE CBA WEBSITES COLLECT?
If you create or log in to an Account or if you utilize the Chat functionality through the CBA websites, we collect and store Personally Identifying Information (PII) that you provide to us. PII may include, but is not limited to, your name, email address, home address, zip code, or telephone number. Additionally, we collect and store any other information that you provide to us such as account payment information.
USE AND DISCLOSURE OF INFORMATION
Any PII or other information that you provide to us is used for such purposes as responding to your requests, collecting your debt(s), communicating with you, and customizing or improving the CBA websites. We may share information you provide us with third parties, including our vendors and service providers, as permitted by applicable law, to perform certain services on behalf of us for the purpose of debt collection. Information that we share for this purpose is limited to only the information which in our discretion is necessary for the third party to perform their function for us as it relates to the collection of debt.
We may access, use, preserve, transfer and disclose your Usage Information, PII, or other information you provide us to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests, or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the CBA Websites’ Terms and Conditions or other policies applicable to the CBA Websites, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the CBA or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use Usage Information, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers, and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.
We may share your Usage Information, PII, or other information you provide us with our subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner, or operator of the CBA Websites or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.
We restrict access to Customer Information about you to those employees or service providers who need to know that information to service your account(s). We maintain physical, electronic, and procedural safeguards that comply with applicable laws and regulations to guard your Customer Information. Whenever we hire third parties to provide support services to help us service or manage your account(s), we will require them to conform to our privacy standards and to allow us to audit them for compliance. Such third parties and their employees receiving Customer Information we have obtained about you are required to limit their use of your Customer Information to the particular purpose for which it is shared, and they are not allowed to share it with others except to fulfill that limited purpose.
YOUR CONTROL OF YOUR INFORMATION
You may have the right to request that we not disclose or restrict our disclosure of certain personal information we collect. You may request that we update or correct your Personally Identifying Information or change your preferences with respect to communications and other information you receive from us. If we receive a verifiable request by an authorized individual, all personally identifiable information we store will be updated, corrected, or changed, as appropriate, as soon as and to the extent reasonably practicable.
LINKS TO OTHER WEBSITES
OTHER APPLICABLE POLICIES
We may revise this Policy at any time, at our sole discretion, by posting an amended Policy on the Site. You can review the current policy at any time by clicking the link at the bottom of every page on the Site.
For questions concerning this Notice or to obtain a copy of this Notice in an alternative format please call us at 888-306-2045 or email us to Attn: Privacy Officer at firstname.lastname@example.org.
CALIFORNIA PRIVACY NOTICE
The CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights.
You have the right to request that CBA disclose certain information to you about our collection of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources from which your personal information was collected.
- The categories of your personal information that we disclosed for a business purpose.
- The categories of third parties to whom your personal information was disclosed for a business purpose.
- Our business or commercial purpose for collecting your personal information.
- The specific pieces of personal information we collected about you.
Right to Non-Discrimination:
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
You have the right to request that CBA delete any personal information about you that we have collected from you. However, this right does not apply where we need to retain the personal information to do any of the following:
- Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between CBA and you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 of Title 12 of Part 2 of the Penal Code;
- 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent;
- To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with CBA;
- Comply with a legal obligation; or
- Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Additionally, in the context of our role as a service provider, we are not obligated to comply with requests to delete information which is collected or maintained in our role as a service provider. Furthermore, requests to delete may be denied if deletion could restrict our ability to comply with federal, state or local laws, as well as our ability to exercise or defend legal claims.
If there are no applicable exclusions, once we receive your verifiable consumer request, we will delete any of your personal information which we have collected from you.
Exercising Your Rights
To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 888-306-2045 and asking to speak with our Privacy Officer
- Submitting an emailed request to email@example.com
Only you, or a person that you 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.
You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
To verify your request, we will compare information you provided with the information CBA already has. We will match 2-3 identifying, personal information data points to verify that the request came from the consumer. We cannot provide you with personal information if we cannot verify your identity or your authority to make the request. If we cannot verify the request, we will notify you.
We are both a business and a service provider as those terms are defined by the CCPA. A service provider that is a business shall comply with the CCPA about any personal information that it collects or maintains outside of its role as a service provider. Most of the personal information that we collect or maintain is done in the context of our role as a service provider. If we deny your request under the CCPA because all the information collected or maintained about you has been pursuant to our role as a service provider, we will provide you with the contact information of the business on whose behalf we collect or maintain the information.
Categories of Personal Information Collected
We collect personal information from the following categories of sources:
- Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
- Indirectly from our clients or their agents. For example, through information we collect from our clients while providing services to them.
- Directly or indirectly from activity on our websites. For example, from submissions through our websites or payment portal.
- From third parties that interact with us in connection with the services we perform. For example, from government and/or publicly available data bases.
Purposes for Collection of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- Debt collection.
- To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information for us to process a payment, we will use that information to process said payment.
- To provide you with information or services that you request from us.
- To provide you with email or text alerts and other notices concerning our services.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for collections.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and our clients, including for collections.
- To improve our websites and present its contents to you.
- For testing, research, analysis, and service development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients, or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Categories of Personal Information Sold
The CCPA provides for the right to opt-out of the sale of personal information. However, CBA does not and will not sell, share, rent, or trade your personal information to any third parties for their commercial purposes.
Categories of Personal Information Disclosed
We engage certain trusted third parties to perform functions and provide services to us for a business purpose. We may share your personal information with these third parties, but only to the extent necessary to perform these functions and provide such services. We also require these third parties to maintain the privacy and security of the Personal Information they process on our behalf.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
- Personal identifying information
- Characteristic information
- Retail information
- Professional or employment related information
Categories of Third Parties
We disclose personal information for business purposes to the following categories of third parties:
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
Changes to Our Privacy Notice
We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will notify you by email or through a notice on our websites’ homepage.
This communication is from a debt collector.