CONSUMER/CLIENT PRIVACY POLICY

Last Updated: July, 2023

We at Consolidated Credit (Consolidated) respect your privacy and your desire to keep personal and financial information private. This Privacy Policy is intended to allow you to understand what information we may collect from you, how we may use it, and what safeguards we have in place to protect it. This Privacy Policy governs the privacy policies and processes relating to our website, as well as to our client services.

Our Privacy Policy Principles
In connection with a request for our credit counseling services, you may be required to provide us with certain non-public personal identifiable information (“PII”) and non-public personal financial information (“PFI”). As part of this process you understand and agree that it may be necessary to share certain PII and PFI with your creditors as part of the credit counseling services. Consolidated does not share your PII and PFI with any non-affiliated third parties other than those who help us in providing assistance to you, and they are required to maintain it in strict confidence. We do not sell your PII or PFI to any outside marketer. We maintain practices and procedures designed to ensure the security, integrity, and confidentiality of your PII and PFI. Some these practices and procedures include: (i) requiring all of our employees to execute non-disclosure and confidentiality agreements; (ii) we educate and train our employees about safeguarding client PII and PFI in order to prevent unauthorized access, disclosure, or use; (iii) we limit employee access to client PII and PFI to those preforming necessary functions in assisting clients, such as yourself, during the credit counseling process. We may collect other Information which is defined as any information other than Personal Information that does not reveal your specific identity or does not directly relate to an individual, such as browser information, information collected through cookies, pixel tags and other technologies, demographic information, aggregated and de-identified data.

What personal identifiable information and/or personal financial information may/do we collect?
We may collect non-public PII and PFI about you from the following sources:

• Information we receive from you on applications or other forms submitted by you, whether submitted through the Internet or manually, as well as through face-to-face conversations, telephone calls, our web-portal, and e-mail communications. This information may include, but is not limited to:
    • Personal Identifiable Information or PII, such as your name, physical address, e-mail address, telephone number, and social security number.
    • Personal Financial Information or PFI, such as your creditors’ names and addresses, the amounts you owe your creditors, your credit card account or creditor account numbers (as applicable), your credit report and/or credit score, banking information (e.g. bank name, bank routing number, bank account number, account holder names, and bank phone number and address), and your income and living expenses.

• Information may developed internally as part of your interaction and transactions with us.
• Information we may receive from your creditors (e.g. statements, balances, requests, letters, etc.).
• Certain information is collected by most browsers and/or through your device, such as your Media Access Control (MAC) address, device type, screen resolution, operating system version and internet browser type and version. We use this information to ensure websites function properly, for fraud detection and prevention, and security purposes.

How do we protect information?
Who has access to your information? All our employees and service agents are required to maintain confidentiality of any PII or PFI that they are given access to as part of their employment. Despite all of our employees and service agents having an obligation to maintain private your PII and PFI, not all employees or servicing agents are given access to your PII or PFI. Only those employees or servicing agents who might need to know your non-public PII or PFI in order to provide you with assistance during the credit consolidation process have access to such information.

Where is the information stored?
All PII and PFI is stored on secured servers, which are constantly updated with the latest security protocols. We may also process and store your personally identifiable information on a server located outside of your jurisdiction. By providing your Personally Identifiable Information to us, you consent to the transfer of your information across national boundaries. If you do not consent to such transfer as well as the processing and storage of your personally identifiable information outside your jurisdiction, you should not provide such information to us.

What information may/do we disclose?
In the course of the credit counseling process, and in order to assist you with your financial situation, we may be required to disclose certain PII and/or PFI on your behalf, including:

    • Information we receive from you on applications or other forms submitted by you, whether submitted through the Internet or manually, as well as through face-to-face conversations, telephone calls, our web-portal, and e-mail communications. This information may include, but is not limited to:

• Personal Identifiable Information or PII, such as your name, physical address, e-mail address, telephone number, and social security number.
• Personal Financial Information or PFI, such as your creditors’ names and addresses, the amounts you owe your creditors, your credit card account or creditor account numbers (as applicable), your credit report and/or credit score, banking information (e.g. bank name, bank routing number, bank account number, account holder names, and bank phone number and address), and your income and living expenses.
• Information may be developed internally as part of your interaction and transactions with us.
• Information we may receive from your creditors (e.g. statements, balances, requests, letters, etc.).
To whom may/do we disclose information?
We may disclose non-public PII or PFI about you to your financial service provider such as banks, creditors, saving and loans, credit unions, mortgage bankers, finance companies, and credit card issuers. For the purpose of fulfilling our mission and providing you with certain services and to process your requests and payments, we may disclose your PII or PFI to one or more service providers or other third parties who are assisting us in performing such services, all of which are required to maintain such information private. Without limiting the foregoing, these third parties may provide us with data management, payment processing, and similar services. Additionally, in the event that you fail to complete a program you enroll in, information may be referred to a servicing agent to contact you to provide additional financial services that you may want to consider.

We also share non-personally identifiable information about our user base with our advertising affiliates who drive traffic to our website to help them identify and target our ideal customer. These affiliates do not use such information for their own direct marketing purposes and do not disclose the information to other third parties for marketing purposes.

You also understand that we may be required to disclose certain PII or PFI in response to a subpoena or court order, or when required by law or when we in good faith believe disclosure is required by law, or to enforce our agreement with the client, and any other terms and conditions or polices.

In addition, should we be unable to assist you we may, with your permission, transfer/transmit any data collected during your session with our counselors to another third party service provider, which may be able to provide you with certain debt relief services.

For what purpose may/do we use information?
We may use non-public PII or PFI for the following purposes:

    • Provide you with credit consolidation services and/or credit counseling guidance;
    • Communicate with your creditors in effort to assist with your debt management program;
    • Communicate with trusted third-parties if our credit counselors determine that you may not fit our program and you wish to hear of other options to assist with your financial situation;
    • Educate you about various ways to improve your financial situation; and
    • Assist you to receive funds from various government assistance programs.
    • Verify your identity and/or location (or the identity or location of your representative or agent) in order to allow access to your services, conduct online transactions and to maintain measures aimed at preventing fraud and protecting the security of your personal information
    • For business purposes, including data analysis, audits, developing and improving products and services, enhancing the website, identifying usage trends and determining the effectiveness of promotional campaigns
    • For risk control, for fraud detection and prevention, to comply with laws and regulations, and to comply with other legal process and law enforcement requirements

Do I have a right to be forgotten/deleted?
Some states have allowed consumer to request that any PII belonging to them be deleted. You understand that because Consolidated is required to maintain files for a certain period of time, it cannot upon request delete PII belonging to the client, which must be maintained by Consolidated to comply with regulatory requirements.

Privacy Terms regarding use of our website:
Websites, by their nature, collect certain information automatically from the users interacting with them. Consolidated Website is no different. In addition to any PII that users may provide through our website (e.g. name, address, phone number, basic financial information (if applicable), etc.), our website collects certain information automatically.

This section of the privacy policy will address clients and non-clients privacy terms when interacting with our website.

1. This section of the privacy policy will address clients and non-clients privacy terms when interacting with our website.
IP Address – An IP address is a unique address associated with your device or network. IP addresses are automatically logged along with the domain name which you are using at the time accessing our website. This information is logged and stored by Consolidated purely as a means of viewing website hits and traffic. Except as is discussed below in “Other technologies including pixel tags, web beacons, and clear GIFs,” this information is not given to, or shared with any third parties for any reason and is erased from our database on a regular basis. Your IP addresses are not used for any purpose other than those stated in this Privacy Policy.

Cookies – Cookies are small files that are downloaded by some websites to store a packet of information on your browser. Companies and organizations use cookies to remember your login or registration identification, site preferences, and pages viewed, so that the next time you visit a site, your stored information can automatically be pulled up for you. A cookie is obviously convenient but also presents potential security issues. You can configure your browser to alert you whenever a cookie is being sent. You can refuse to accept all cookies or erase all cookies saved on your browser. We use cookies as a means of identifying repeat visitors. Changing your web browser’s setup to “reject” cookies does not prevent a user from visiting any portion of our website.

Other technologies including pixel tags, web beacons, and clear GIFs - These may be used in connection with some website pages, downloadable mobile applications and HTML-formatted email messages to measure the effectiveness of our communications, the success of our marketing campaigns, to compile statistics about usage and response rates, for fraud detection and prevention, for security purposes, for advertising, and to assist us in resolving account holders’ questions regarding use of our website. You understand and agree that we may use third party pixel tags, web beacons and/or clear GIFs that may give access to third parties to your information, including your IP address and browsing activities on pages of our websites where these devices are placed. You understand that we do not control any information gathered by such devices or their use by such third parties. Please see our Advertising section below for more information regarding our use of other technologies.

Google Analytics- We use a tool called “Google Analytics” to collect information about use of this website. Google Analytics collects information such as how often users visit this website, what pages they visit when they do so, and what other sites they used prior to coming to this website. We use the information we get from Google Analytics only to improve this website. Google Analytics collects only the IP address assigned to you on the date you visit this website, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this website by disabling cookies on your browser.

Third party widgets – We may allow certain widgets (e.g., social share buttons) on our websites that enable users to easily share information on another platform, such as a social media platform. The third parties that own these widgets may have access to information about your browsing on pages of our websites where these widgets are placed. You may wish to review information at the third party site, such as social media platforms where you have an account, to determine how these third parties collect and treat such information. Also, see Linking to other sites and Social media sites below.

Retargeting – As you browse consolidated credit, advertising cookies will be placed on your computer so that we can understand what you are interested in. Our display advertising partners, enable us to present you with retargeting advertising on other sites based on your previous interaction with consolidated credit. The techniques our partners employ do not collect personal information such as your name, email address, postal address or telephone number.

Google Interest Based Advertising Program – In order to enhance your experience when you visit our website, we participate in the Google Interest-based Advertising Program (“Program”) to ensure the advertisements on this website correspond to your interests. We do this by working with Google and other Program participants who, like us, place ads on our website and those of other Program Participants. We then share the information we collect using Web Cookies placed in your browser in order to provide you with targeted advertising when you visit the website. You may opt out of Google’s use of cookies by visiting the Google Advertising Opt-Out Page

2. What are the external links and why are they on our website?
Moreover, certain links to Facebooks are operated pursuant to their terms of service and privacy policy. Facebook owns and operates each of the companies listed below, in accordance with their respective terms of service and privacy policies. We may share information about you within the Facebook family of companies assist in advertising our services. For more information on the Facebook Companies’ privacy practices and how they treat individuals’ information, please visit the following links:

• Facebook Payments Inc. (https://www.facebook.com/payments_terms/privacy)
‍• Facebook (https://developers.facebook.com/policy)
‍• Facebook (https://www.facebook.com/about/privacy/)
‍• Facebook (https://www.facebook.com/legal/terms)
‍• Instagram LLC TOS (https://www.instagram.com/about/legal/terms/)
‍• Atlas (https://www.facebook.com/business/measurement/privacy-policy)
‍• Instagram LLC (http://instagram.com/about/legal/privacy/)
‍• Parse (https://opencollective.com/privacypolicy)
‍• Oculus (https://www.oculus.com/legal/privacy-policy/)
‍• LveRail (https://www.facebook.com/audiencenetwork/privacy-policy)
‍• WhatsApp Inc. (https://www.whatsapp.com/legal/)

3. What are third-party beacons?
We use third-party web beacons from Yahoo! to help analyze where visitors go and what they do while visiting our website. Yahoo! may also use anonymous information about your visits to this and other websites to improve its products and services and provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by Yahoo! visit https://yahoo.mydashboard.oath.com/device/ to learn how to opt out of this service.

4. How do I access my account through the Member Portal on our website?
Member Portal – The Member Portal is a useful tool for our members who have enrolled in Consolidated’s debt management program. Members may choose to register into our portal which contain specific member information and allows the member to: (i) update personal details; (ii) access member’s accounts and manage the member’s creditor account information; (iii) track upcoming payments due on your account; and (iv) communicate with our customer service specialists. In order to register to the Member Portal you will need to register a Username and Password. This username and password is unique to you. DO NOT SHARE IT WITH ANYONE, UNLESS YOU SPECIFICALLY AGREE TO PROVIDE THEM WITH ACCESS TO YOUR ACCOUNT. Consolidated will not be responsible for unauthorized access by those whom you shared your account information with as it cannot validate that it was not you who accessed it. If you are logging into member portal from a public computer, or through a public wifi. Such connections may not be secured and may expose your financial information to others. If you choose to maintain your information private do not log in using public access points. If you believe you were subject to unauthorized use and your password has been breached, please reset your password immediately and let us know if there are unauthorized changes on your account. If you fail to let us know of any unauthorized action, we will presume you made and authorized the changes in your account. If you forget your password, you may use the Forget Password tool to retrieve or replace your password.

5. No collection of PII belonging to minors under 13
The website is not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the website. We do not knowingly collect information from children under 13 years of age without parental consent If you are a User under the age of 13, please do not send any Personal Information to us if we have not obtained prior consent from your parent or guardian. If we learn we have collected Personal Information from a User under the age of 13 without parental consent, or if we learn a User under the age of 13 has provided us Personal Information beyond what we request from him or her, we will delete that information as quickly as possible. If you believe that a User under the age of 13 may have provided Consolidated Personal Information in violation of this Privacy Policy, please contact us at our e-mail or physical mailing address listed in the “Contact Us” section below and we will take all reasonable efforts to remove the information. For more information about the Children’s Online Privacy Protection Act (COPPA), please visit the Federal Trade Commission website at https://www.ftc.gov/business-guidance/privacy-security/childrens-privacy.

Social media sites
Consolidated Credit provides experiences on social media platforms that enable online sharing and collaboration among users who have registered to use them. Any content you post on official Consolidated Credit managed social media pages, such as pictures, information, opinions, or any Personal Information that you make available to other participants on these social platforms, is subject to the Terms of Use and Privacy Policies of those respective platforms. Please refer to them to better understand your rights and obligations with regard to such content. In addition, please note that when visiting any official Consolidated Credit social media pages, you are also subject to Consolidated Credit‘s Privacy Notices.

Short Message Service (“SMS”) Use:
Consolidated may make available a service through which you can receive financial guidance and account notification on your wireless device using short message service (“SMS Service”). One (1) message is sent per week. Consolidated collects certain data from you in connection with this SMS service which may include your name, address, cell phone number, your provider’s name, and the date, time, and content of your messages.

To use this service you must be at least 18 years of age and the owner or authorized user of the wireless device on which messages will be received. By agreeing to our SMS Service, you acknowledge that you are at least 18 years old, that you are either the owner or authorized user of the wireless devise, and that you understand and agree that this service may be subject to an additional fee (if applicable). In addition to any fee of which you are notified, your provider’s standard message and data rates may apply to our confirmation and all subsequent SMS correspondence. All charges are billed by and payable to your mobile service provider. Consolidated will not be liable for any delays in the receipt of any SMS messages, as delivery is subject to effective transmission from your network operator. SMS message services are provided on an AS IS basis.

We will use the information we obtain in connection with our SMS Service in accordance with this Privacy Policy. If fees are charged to your wireless account invoice, we may provide your carrier with your applicable information in connection therewith. Your wireless carrier and other service providers may also collect data about your wireless device usage, and their practices are governed by their own policies. Consolidated is not responsible for any information collect by your carrier. Please consult the carrier’s privacy policy.

You acknowledge and agree that the SMS Service is provided via wireless systems which use radios (and other means) to transmit communications over complex networks. You must have a two-way text-enables phone with compatible carrier and plan. Compatible major carriers include Alltel Wireless, AT&T, Boost Mobile, Nextel, Sprint, T-Mobile, Verizon Wireless and Virgin Mobile USA. We do not guarantee that your use of the SMS Service will be private or secure, and we are not liable to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the SMS Service. We may also access the content of your account and wireless account with your carrier for the purpose of identifying and resolving technical problems and service-related complaints.

SMS and Phone Call Opt-In and Opt-Out
By providing your phone number and/or joining our SMS Service, you authorize Consolidated to contact you (including using autodialers, automated text and pre-recorded messages) via your telephone, cellphone, mobile device (including SMS and MMS) and email, even if your telephone number is currently listed on any state, federal or company’s Do Not Call list. Standard phone and data charges will apply. Your consent to the above terms is not required as a condition of purchasing or receiving our services. You also consent to the recording and monitoring of all calls to and from us. You may opt out of receiving such phone calls or text messages to your mobile device at any time by emailing us your instructions at privacy@consolidatedcredit.org. You may also opt-out and remove your authorization to receive SMS text messages by replying with “STOP”, “END”, “QUIT”, “UNSUBSCRIBE”, or “CANCEL” to any SMS you receive or by going to Members of Consolidated Credit.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Security
At Consolidated, the security of your personal information is extremely important to us. We take commercially reasonable precautions to protect your personal information and only provide employees access to it on a need-to-know basis. In an effort to prevent the unauthorized access, disclosure, dissemination, misuse, loss, alteration or destruction of your personal information, we have employed commercially reasonable physical, electronic, and managerial measures to protect your data and we periodically review these policies and procedures to prevent these types of acts. However, despite our best efforts, no security policy, procedures or practices are adequate to protect against all types of threats or data losses and no type of data transmission method is impenetrable to interception.

Newsletters and E-mail Communications:
When you provide your e-mail address on any form or as part of any request for information, you will be automatically enrolled in our e-mail newsletter, and agree to receive email communications. You can opt-out or unsubscribe from our newsletter or other e-mail list at any time by following the instructions at the end of the newsletter or e-mail you receive. Please allow at least ten (10) business days for changes to take effect. You understand that until the opt-out takes effect you may still receive some electronic communications or newsletters. Client service-related communications are an integral part of the services which you receive from us, and you may continue to receive such service-related emails even if you opt out of the newsletters or email list. If you have provided more than one e-mail address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided. You may also opt-out of receiving our newsletter or marketing emails by contacting us at unsubscribe or by replying to an existing email with your request to be removed from the mailing list or click here.

State Specific Notices:
    1. Notice to California Residents - Residents of the State of California may request a list of all third-parties to which this website has disclosed certain information during the preceding year for those third-parties’ direct marketing purposes. If you are a California resident and want such a list, please contact us at privacy@consolidatedcredit.org. For all mailed requests, you must put the statement “California Privacy Request” in the body of your request, as well as your name, street address, city, state, and zip code. Please note that we are not responsible for requests that are not labeled or sent properly, or that do not have complete information.

    2. Notice to Vermont Residents - Based on your consent, Consolidated may share your information with nonaffiliated third parties to the extent authorized by this Privacy Policy and as allowed by Vermont regulations. As stated above, you may withdraw your consent to such sharing at any time by emailing us your requests at privacy@consolidatedcredit.org and/or setting your browser not to allow cookies from our website and/or changing your Privacy settings on other sites, such as those operated by the Facebook Companies, as appropriate.

    3. Notice to Nevada Residents - We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by following the directions set forth above. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; e-mail: BCPINFO@ag.state.nv.us.

    4. Notice to Users Outside of the United States - This Privacy Policy is intended to cover collection of information on our websites from residents of the United States. If you are visiting our websites from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our central database is operated. The data protection and laws of the United States and other countries might not be as comprehensive as those in your country. By using our services, you understand that your information may be transferred to our facilities and those third-parties with whom we share it as described in this Notice.

Revised Privacy Policies
We reserve the right to change, modify, or amend our privacy policy and practices from time to time, and that we may do so by simply by posting a revised Privacy Policy on our Website www.consolidatedcreditsolutions.org. Any such change shall be effective immediately upon posting of the revised Privacy Policy on the website, and will apply to any PII or PFI in our possession at the time or as we may obtain as pard of the services in the future. We may provide you with an electronic link to the revised Privacy Policy, or if you have opted out of electronic communication you may receive a copy of the revised Privacy Policy by mail to your last known address. You should refer to this Privacy Policy on an ongoing basis so that you are aware of our current privacy practices.

Questions, Corrections, or Inquiries regarding the Privacy Policy
If you have any question about our privacy policy and practices please contact us at (954) 377-9240. If you want to correct any personal information in our files, please submit a written request to us to: privacy@consolidatedcredit.org. Thank you for choosing Consolidated to assist you in restoring your financial well-being.