CBCS has created this privacy statement in order to demonstrate our commitment to your privacy. We respect your privacy and will not sell, lease or distribute your information gathered from the IP address.
Effective Date: 07/1/2020
SCOPE OF THIS POLICY
The CBCS website located at www.cbcsnational.com (its "website") and www.cbcspayments.com is not intended for individuals less than the age of eighteen and CBCS does not knowingly collect data relating to individuals less than the age of eighteen.
Nothing in this privacy statement is intended to contradict your rights under the Fair Debt Collection Practices Act. CBCS will not disclose any information to third parties that is otherwise prohibited by the FDCPA.
Our website is not directed at children under the age of 13.
CHANGES TO THIS POLICY
INFORMATION AUTOMATICALLY COLLECTED
When you visit the website, we automatically collect certain information, like your IP address, browser type and operating system, the domain from which you came, the page you are viewing, and the date and time of your visit.
We use this information for a number of purposes, such as investigating security incidents, running analytics to understand usage, and for compliance with security standards.
We do not collect personal information when you visit our website, unless you choose to provide it to us. You may elect to share personal information with us by filling out the information on our Contact CBCS page, such as name, address, phone number, email address, and any other personal information you choose to provide. You may also elect to share personal information with us by emailing us using the links on our website.
We use information you send to us to respond to your inquiries or comments.
We may have collected the following categories of personal information from consumers within the last 12 months:
|Categories of Personal Information||Examples of Specific Types of Personal Information Collected|
|A. Identifiers||A real name, alias, postal address, email address, telephone numbers, Internet Protocol address, account number, Social Security number, date of birth, or other similar identifiers.|
|B. Personal Information||A name, signature, Social Security number, physical characteristics or description, address, telephone number, driver's license or state identification card number, insurance policy number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.|
|C. Protected classification characteristics||Age (40 years or older), language, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.|
|D. Internet or other electronic network activity information||Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.|
|E. Sensory data||Audio.|
|F. Professional or employment-related information||Current or past job history.|
|G. Inferences drawn from any of the information identified above||Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.|
HOW WE USE YOUR INFORMATION
Personal information is collected solely for the purpose of debt recovery in a lawful manner and remains part of our records until we determine the information is no longer needed, or we are required by law to delete such information. We will collect the minimum amount of data necessary to collect a debt. Your personal information may be used to fulfill or meet the reason you provided such information. Your personal information will also be used to perform services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, verifying customer information, processing payments, providing analytic services, or providing similar services.
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.
SALE OF PERSONAL INFORMATION
We do not sell and will not sell your personal information.
HOW WE COLLECT YOUR INFORMATION
We collect most of this personal information directly from our clients for whom we provide services to, as well as from you by telephone, written correspondence through the mail, email or fax, by viewing public social media/network pages, or other information available online. However, we may also collect information:
- From publicly accessible sources (e.g., property records or court records);
- From your transactions with us;
- From our service providers (e.g., letter vendor, location vendors, payment processing vendors, call analytics vendor, and/or electronic signature service provider);
- Directly from a third party (e.g., third parties contacted during location activities pursuant to 15 U.S.C. §1692b, such as your friends, neighbors, relatives, and/or employer);
- Consumer reporting agencies (CRAs)
- From a third party with your consent (e.g., your authorized representative and/or attorney); and
- From activity on our website.
We use the information we get from Google Analytics to understand how our website is used and make improvements.
THIRD-PARTY LINKS AND WEBSITES
You may be able to access third-party sites by clicking links on our site. We are not responsible for the privacy policies or practices of any third-party sites, and if you visit those websites, we encourage you to review their respective privacy policies.
CHOICE & ONLINE TRACKING
As a user of our website, you control whether to send us personal information by using our Contact CBCS form.
CBCS does not track your online activities over time and across third party websites. However, other third parties may be conducting online tracking on our site. To learn more about the choices you have regarding online tracking, please visit these sites:
INFORMATION SHARING AND DISCLOSURE
CBCS may share personally identifiable information it collects with its employees who need to know that information to provide services to you. Except as provided below, CBCS does not share or disclose any personally identifiable information with any company or marketing group external to CBCS. CBCS may share your personal information with third parties to the extent it is reasonably necessary to manage or service your account, verify employment, determine location, process payment, fulfill a transaction, provide customer service, or as otherwise authorized by law.
Further, CBCS may disclose personally identifiable information (i) to another entity with which CBCS enters or reasonably may enter into a corporate transaction, such as, for example, a merger, consolidation, acquisition, or asset purchase, (ii) to a third party pursuant to a subpoena, court order, or other form of legal process or in response to a request by or on behalf of any local, state, federal, or other government agency, department, or body, whether or not pursuant to a subpoena, court order, or other form of legal process, or in connection with litigation brought against, or on behalf of, CBCS, where appropriate, (iii) to a third party if determined by CBCS in its sole judgment that such disclosure is appropriate to protect the life, health, or property of CBCS or any other person or entity, all in compliance with applicable law, (iv) to third parties as authorized or designated by you, or (v) to conduct any other legitimate business activity not otherwise prohibited by law. The foregoing is not intended to obviate or displace any legal obligations or duties applicable to CBCS.
SHARING YOUR INFORMATION WITH CONSUMER REPORTING AGENCIES
Consumer Reporting Agencies (CRAs) collect and maintain information on consumer and business credit profiles on behalf of organizations in the United States. We may share information about you with CRAs and may carry out periodic searches with them to verify your identity or manage your account.
Details of your account(s) with us may be sent to CRAs and recorded by them. This information may be supplied by CRAs and may be used and searched by us and other organizations, such as debt collection agencies, in order to:
- consider applications for credit and credit related services;
- locate debtors and recover debts; and
- manage your accounts.
CBCS may furnish account information to Experian, Equifax, and Trans Union. You have a right to obtain an annual copy of your credit file from CRAs by visiting https://www.annualcreditreport.com.
HOW LONG WE KEEP YOUR INFORMATION
CBCS may retain your personal data for up to 7 years, or as otherwise required by law or pursuit to contractual obligation. CBCS thereafter deletes or anonymizes such information in accordance with applicable laws.
ACCESS AND CORRECTION OF PERSONAL INFORMATION
You may access and update personal information you have provided through our website either by submitting updated information using our online Contact CBCS form, or by contacting us at the address or telephone number listed below.
P.O. Box 163250
Columbus, OH 43215
SECURITY AND CONFIDENTIALITY
CBCS strives to protect personal information that we collect, maintain, and disclose through the use of reasonable administrative, physical, and technical safeguards. Personal information submitted online is transmitted through transport layer security (TLS), which is a protocol for establishing a secure connection for transmission. Our security program is designed to: (1) ensure the security and confidentiality of personal information, (2) protect against any anticipated threats or hazards to the security or integrity of the information, and (3) protect against unauthorized access, alteration, and unlawful disclosure of the information. We dispose of such information by taking reasonable measures to protect against unauthorized access to or use of the information.
CALIFORNIA RESIDENTS - YOUR LEGAL RIGHTS
- The right to access personal information - You have the right to request access to your personal information that we collected about you, subject to certain exceptions.
- The right to delete personal information - You have the right to request that we delete your personal information, however, state and federal law or contractual obligations may prohibit us from deleting personal information, which CBCS will disclose to you.
- The right to non-discrimination - We will not discriminate against you if you exercise any of these rights.
- The right to an authorized agent - You can designate an authorized agent to make any of these requests by providing your express written authorization. We must be able to verify your identity and the authorization must include the authorized agent’s name, address, telephone number, and email address, if applicable (for providing the personal information collected or to respond to a request for deletion).
If you wish to exercise any of these rights, please contact CBCS by doing one of the following:
- Submit online to email@example.com
- By mailing a request to: PO Box 965, Columbus, OH 43216
- Toll free telephone: 1-855-202-0113
If you choose to contact directly by [email/phone/in writing], you will need to provide us with:
- Enough information to identify you [e.g., your full name, address and customer or matter reference number];
- Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
- Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
POINT OF CONTACT
Attn: Consumer Assistance
PO Box 965
Columbus, OH 43216