California Privacy Notice

Under the CCPA and CPRA, California residents have specific rights with respect to their personal information. Certain information we process in connection with debt collection is exempt from parts of these laws because it is regulated by the FDCPA, the FCRA, or the GLBA. Where an exemption applies, we describe our practices for transparency even when the specific right is not required by law.

In the past twelve months we may have collected the following categories of personal information about California residents:

• Identifiers — name, postal address, email, telephone number, account or reference number, and, where legally required, Social Security number.
• Customer records (Cal. Civ. Code § 1798.80(e)) — additional identifying information provided in connection with a debt.
• Commercial information — records of the debt, transaction history, and payment history.
• Financial information — bank account and payment card information used to make a payment.
• Internet or other electronic network activity — website interaction data, IP address, and device information.
• Audio and electronic information — recordings of telephone calls with our representatives.
• Professional or employment-related information — limited employment information provided by the consumer or lawfully obtained for locating purposes.
• Inferences — inferences drawn to service the account, such as best contact time or preferred channel.

We may process sensitive personal information as defined by the CPRA — for example, a Social Security number or a bank account number provided to make a payment. We use sensitive personal information only for the purposes permitted by the CPRA, such as providing the service requested, preventing fraud, and complying with law. We do not use sensitive personal information to infer characteristics about a consumer.

Personal information is obtained from:

• Original creditors and prior servicers.
• Consumers themselves, directly or through authorized representatives.
• Consumer reporting agencies and permissible skip-tracing databases.
• Government records and court filings.
• Our service providers.
• Your device and browser when you interact with this website.

We use personal information for the purposes described in Section 4 of our Privacy Policy, including:

• Servicing, collecting, and resolving placed accounts.
• Verifying identity and locating consumers within legal limits.
• Processing payments and issuing receipts.
• Investigating and responding to disputes, complaints, and requests.
• Meeting legal, regulatory, examination, and audit obligations.
• Preventing and investigating fraud and unauthorized activity.
• Operating and improving this website.

Categories of third parties to whom we may disclose personal information for a business purpose:

• The original creditor or its authorized servicer.
• Attorneys, licensed process servers, and courts in permitted legal actions.
• Payment processors, mailing houses, telephony providers, and cloud infrastructure providers.
• Consumer reporting agencies where permitted and directed.
• Regulators and government authorities responding to lawful requests.
• Professional advisors such as auditors and outside counsel.

We do not sell personal information as "sale" is defined by the CCPA, and we do not share personal information for cross-context behavioral advertising as "sharing" is defined by the CPRA. We have not sold or shared the personal information of consumers under 16.

We retain each category of personal information for as long as necessary to service the account, satisfy our legal, regulatory, tax, and recordkeeping obligations, resolve disputes, and enforce our agreements. Retention periods vary by category and by applicable state and federal law.

Subject to verification and applicable exemptions, California residents have the right to:

• Know what categories of personal information we have collected, the sources, the purposes, and the categories of recipients.
• Access the specific pieces of personal information we hold about you.
• Correct inaccurate personal information we hold about you.
• Delete personal information we have collected from you, subject to statutory exceptions (including recordkeeping obligations under the FDCPA, the FCRA, and other law).
• Limit the use and disclosure of sensitive personal information, though our uses of sensitive personal information are already limited to purposes permitted by the CPRA.
• Opt out of sale or sharing, though as noted above we do not sell or share personal information.
• Non-discrimination for exercising your rights (see Section 13).

Information that is regulated by the FCRA or the GLBA — including personal information collected, processed, sold, or disclosed pursuant to those statutes — is exempt from certain CCPA/CPRA rights. Where an exemption applies, we will explain the basis when responding to your request.

You can submit a rights request in either of the following ways:

• By calling us toll-free at [TOLL-FREE].
• By submitting our Notice Recipients form and selecting "Set a communication preference" or "Request validation or documentation," or by emailing [PRIVACY EMAIL].

Please provide enough detail for us to identify the account and the request, and specify which right you are exercising.

Before we act on a request to know, access, correct, or delete, we must verify that the person making the request is the consumer whose personal information is at issue. For most requests we will ask you to confirm identifiers already on file, such as name, mailing address, and the last four digits of an account or reference number. We may request additional information for higher-risk requests, and we will use that information only to verify the request.

A California resident may designate an authorized agent to submit a request on their behalf. We will require written authorization from the consumer and verification of the agent's identity, unless the agent has provided a power of attorney in accordance with California law.

We will not discriminate against a California resident for exercising their privacy rights. Specifically, we will not deny goods or services, charge different prices, or provide a different level or quality of services because you exercised a right.

California privacy requests and questions may be directed to: