CREDIT COLLECTION SERVICES

COMMERCIAL

725 Canton Street, Norwood, MA 02062 - 617.843.7700

California Residents click here

Privacy Notice

This Privacy Notice effective as of 12-20-2019 sets forth our information gathering, use, and dissemination practices in connection with our web sites, including those located at www.ccscommercial.com and any others that we may now or in the future establish ("Websites").

This Privacy Notice only addresses our practices regarding information collected directly through or from its Websites - it does not address or govern any information gathering, use, or dissemination practices related to information collected in any way other than directly through or from its Websites; i.e. this policy does not address our privacy practices associated with information we may obtain through any other means, including, without limitation, from or via telephone, facsimile, postal mail, personal delivery, or other or additional online or offline means or media.

We do not sell, share or otherwise disseminate any information we may receive from you through our Websites except as set forth below. We may collect, use, and/or store information that you use to access the Websites, the Internet address of the site from which you linked directly to the Websites, the date and time of your visit to the Websites, as well as any information that you may enter on the Websites. This information may be used by us internally for any purpose, including, but not limited to measuring the number of visitors to the various pages on the Websites and to help make improvements to the information contained on the Websites. We may also collect, use, and store the e-mail addresses of users that communicate with us via e-mail, information knowingly provided by Websites users, and information regarding which pages on the Websites that users access.

We may share personally identifiable information obtained on the Websites with any company internal to us or our affiliates. Except as provided below, we do not share any personally identifiable information obtained on the Websites with or sell information obtained on this Websites to any company or marketing group external to us and our affiliates. We may, however, share aggregate information with other persons or entities for purposes determined by us to be appropriate.

We may disclose identifiable information (i) to another entity with which we enter 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, (iii) to a third party if determined by us in our sole judgment that such disclosure is appropriate to protect the life, health, or property of us or any other person or entity; (iv) to our clients; or (v) to internet service providers, payment processing companies and other third parties with whom we have contracted to provide services related to our Websites. Notwithstanding the foregoing, the list or possible recipients of information is not intended to obviate or displace any legal obligations or duties applicable to us.


E-mail posted or sent through the Websites or addressed to any URL operated by us may not be secure against interception by unauthorized individuals. To protect against interception by unauthorized individuals, we may not respond to e-mail communications. Therefore, if you are communicating with us regarding a matter with our office all correspondence regarding that account should be sent by facsimile, by U.S. Postal Service or via our online correspondence tool where applicable. Be sure to include your name, your mailing address, CCSC file number, our client's name, and the client's account number so that we may locate the account and process your inquiry and respond promptly. Without complete information, we will be unable to respond to your request. The address for mailing inquiries is:


CCS Commercial, LLC
725 Canton Street
Norwood, MA 02062


We may change this Privacy Notice at any time with or without notice. It is the obligation of users visiting the Websites to review the Privacy Notice on each subsequent visit to determine if the Privacy Notice has been updated or changed since their last visit. Any change to this Privacy Notice shall be effective immediately upon updating the Privacy Notice on the Websites.

Do Not Track requests: We do not track any information about your navigation or any other activity outside of our sites. Any data we receive as a result of your interaction with our site is not released outside of our corporate environment nor do we utilize this data other than for internal purposes.

The information contained in this privacy policy pertains to CCS Commercial LLC dba Credit Collection Services Commercial.

The CCS Companies

Supplemental Privacy Policy

For California Residents

 

This Privacy Policy is for California residents, and supplements the information contained in our general Privacy Policy set forth here. We adopt this policy to comply with the California Consumer Privacy Act (“CCPA”). Any terms defined in the CCPA have the same meaning used in this policy. In the event of any conflict between this policy and our general policy, this policy will control with respect to California Residents.

1. Information We Collect About You


We may collect and use the following 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”). We 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 categories listed in California Customer Records Statute (Cal. Civ. Code §1798.80(e)):

 

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, 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 under California or Federal law:

 

Age (including whether you are 40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, 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. Commercial information:

 

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

E. Biometric Information:

Currently not collected.

F. Internet or other electronic network activity information:

Browsing history, search history, and information regarding a consumer’s interaction with our Internet Web site.

G. Geolocation data:

Currently not collected.

 

H. Sensory data:

 

Not applicable; notwithstanding, The CCS Companies does record phone calls.

I. Professional or employment-related information:

Current or past job history.

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)):

Currently not collected.

 

K. 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

 

Personal Information does not include:

  • Publicly available information from government records.

  • Deidentified or aggregated consumer information.

  • Information excluded from the CCPA's scope, like:

    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

 

2. How Your Personal Information is Collected

We collect most of this personal information directly from our clients to whom we provide services, as well as from you by telephone, written correspondence through the mail, email or fax, by viewing your 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 our service providers (e.g., letter vendor, skip tracing vendors, payment processing vendors, call analytics vendor, and/or electronic signature service provider);

  • Directly from a third party (e.g., third parties contacted during skip tracing activities pursuant to 16 U.S.C. §1692b, such as your friends, neighbors, relatives, and/or employer);

  • From a third party with your consent (e.g., your authorized representative and/or attorney); and

  • From activity on our website.

 

3. Why We Use Your Personal Information

We may use or disclose your personal information for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your personal information to make a payment, we will use that information to process your payment.

  • Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying customer information, processing payments, , providing analytic services, or providing similar services on behalf of the business or service provider.

  • To provide you with information, products or services that you request from us.

  • Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to auditing compliance with this specification and other standards.

  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

  • Debugging to identify and repair errors that impair existing intended functionality.

  • Undertaking internal research for technological development and demonstration.

  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • As necessary or appropriate to protect the rights, property or safety of us, our clients, or others.

  • 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.

 

4. Who We Share Your Personal Information With

 

We routinely share personal information with:

  • Our affiliates, including companies within The CCS Companies;

  • Our clients;

  • Service providers we use to help deliver our services, such as payment service providers, skip trace vendors and others;

  • Other third parties we use to help us run our business, such as marketing agencies or website hosts;

  • Third parties approved by you, including third-party payment providers;

  • Credit reporting agencies;

  • Our insurers and brokers; and

  • Our bank(s) and other financial institutions.

 

In the preceding twelve (12) months, we have not sold any personal information.

 

5. Your Rights

 

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

 

a. Disclosure of Personal Information We Collect About You

You have the right to request that we disclose certain information to you about our collection and use 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 have collected about you.

  • The categories of sources from which the personal information is collected.

  • Our business or commercial purpose for collecting or selling personal information.

  • The categories of third parties with whom we share personal information, if any.

 

Please note that we are not required to:

  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;

  • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or

  • Provide the personal information to you more than twice in a 12-month period.

 

b. 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.

 

c. Deletion Request Rights

You have the right to request that we delete any of your personal information that 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 deletion request if retaining the information is necessary for us or our service providers to:

  • 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 you and us.

  • 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.

  • 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, provided we have obtained your informed consent.

  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.

  • Comply with an existing legal obligation.

  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

 

d. Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

  • Deny goods or services to you;

  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

  • Provide a different level or quality of goods or services to you; or

  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

 

Please note that we may charge a different price or rate, or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to you by your personal information.

6. How to Exercise Your Rights

To exercise the access, data portability, and deletion rights described herein, please submit a verifiable consumer request to us by either:

 

  • Completing a data subject request form available on our website at www.ccsprivacypolicy.com ; or

  • Calling us, toll-free,  at (877) 219-7567 .

 

Please note that you may only make a data access or data portability disclosure request twice within a 12-month period.

 

7. Verifying Your Identity (i.e., verifiable consumer request)

If you choose to contact us directly, you will need to provide us with:

  • Enough information to identify you (e.g., your full name, address and CCS file number found on your notices);

  • 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.

 

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

 

8. Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response to you through the web site, email or US postal mail depending on the manner of your request and any delivery options selected by you. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain any reasons we cannot comply with a request, if applicable.

 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

9. Changes to our Privacy Notice

 

We reserve the right to amend this privacy policy at our discretion and at any time.

 

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