Privacy Policy

Last Updated: 5/30/23

Introduction

This Privacy Policy (the “Privacy Policy” or “Policy”) describes the types of information CB1 Collections (“CB1,” “we,” “our,” or “us”) collects and processes from and about you.  

Except as described in this Privacy Policy, the Policy applies to all websites, mobile applications, and any other electronic and/or digital products and/or other services that are made available by CB1 and that link to this Policy (the “Site”), and our offline debt collection services (collectively with the Site, the “Services”). 

We process the information of Clients (our business customers for which we collect debts), Consumers (individuals who interact with us to pay those debts), and in some cases, third parties.    

Nothing in this Privacy Policy is intended to contradict your rights under the Fair Debt Collection Practices Act (FDCPA).  CB1 will only process your information consistent with the FDCPA and applicable law.

1. Information We Process on Behalf of Our Clients

Our Clients may choose to use the Services to process some of their information. The information that we process through the Services for our Clients is controlled by those clients.  We process that information at the direction of those Clients and our privacy practices governing the processing of that information will be in accordance with contracts that we may have in place with those Clients.

If you have any questions or concerns about how such information is handled or would like to exercise your rights, you should contact the Client who has contracted with us to use the Services to process your information. Our Clients determine how and for what purpose the information collected on their behalf should be processed. We will, however, assist our Clients to address any concerns you may have, in accordance with the terms of our contract with them. 

2. Information We Collect

We collect information about you when you use our Services or when you interact with us. The types of information we collect depend on the services and the features you use on the Services or the nature of our interaction. 

The information we collect may include data you directly provide to us, data we obtain automatically from your interactions with our Services, and data we obtain from other sources.

Information You Provide Directly to Us

We may collect information directly from you when you use the Services or communicate with us.  The types of information we may collect from you directly include:

Clients

• Client ID and username
• Name 
• Email address
• Phone number
• Company
• Address
• Communications with us when you email or call us
• Other relevant information that you provide

Consumers

• Account number
• Name and aliases
• Email address
• Phone number
• Address
• Social security number
• Date of birth
• Account numbers
• Communications with us when you email or call us
• Other relevant information that you provide

Information We Collect Automatically

Log Data.  When you use the Site, we may collect information such as your Internet Protocol (IP) address and/or domain, the type and version of your Internet browser software and operating system you use, the date, time, and duration of your use of the Site, the specific pages, buttons, images, links, and forms that you access while visiting the Site, the type of device you use to access the Site, and your mobile carrier and/or Internet Service Provider. 

Cookies and Similar Technologies.  When you use the Site, we, or our vendors, may place cookies on your browser or other access device.  Cookies are small text files that are placed on your computer by websites that you visit. We and our vendors may also use technologies similar to cookies to track your interaction with the Site, including clear gifs, web beacons, and tracking pixels (together with cookies, “Cookies”).  

Clear gifs, web beacons, and tracking pixels are tiny graphics with a unique identifier. They function similarly to cookies and are used to track the online movements of web users. Unlike cookies which are stored on a user’s computer hard drive, clear gifs are embedded on web pages and are single pixel wide. 

We may also embed web beacons, tags, and pixels in the emails we send to you to help us understand how you interact with those messages, such as whether and when you opened an email or clicked on any content within the email.

Device/Usage Information. We and our third-party service providers, which include analytics companies such as Google Analytics, may use Cookies to collect information about the computers or devices (including mobile devices) you use to access the Site. As described further below, we may collect and analyze information including but not limited to (a) browser type; (b) internet service provider or operating system; (c) domain name; (d) access time; (e) referring or exit pages; (f) page views; (g) IP address; (h) unique device identifiers (e.g. IDFA or Android ID); and (i) the type of device that you use. We may also track when and how frequently you access or use the Site, including how you engage with or navigate our websites. We use this information (including the information collected by our third-party service providers) for analytics (including to determine which portions of the Site are used most frequently and what our users like/do not like), to know when users have accessed the Site from a paid advertiser, an affiliate website, or a strategic partner website, and as otherwise described in this Policy.

Location Information. When you use the Site, we may collect general location information (such as general location inferred from an IP address).

Information We Collect from Other Sources

We may gather information about you, including your contact information, credit information, location data, purchase information, professional and educational information, from third parties.  For example, if you are a Consumer, we collect information about you from our Clients and their agents (see Section 1), from publicly available sources, credit reporting agencies, and in some cases, your friends, neighbors, relatives, or employers.  If you are a Client, we may collect your information if you are referred by another client, or from marketing partner and researchers.  

3. How We Use Your Information

Clients

We may use your information to: 

• Provide information, products, or services to you, including the Services.
• Respond to your comments, questions, and requests, and provide customer service.
• Enforce the agreements between you and CB1. 
• Analyze, improve, modify, customize, and measure the Services. 
• Communicate with you about CB1’s products, services, surveys, events, content, and other information we think may be of interest to you. 
• Personalize and improve the Services and provide content and features that match your profile and interests and remember information about your preferences for the Services.
• Compare information for accuracy and verify our records. 
• Comply with our legal obligations or as permitted by law.
• Protect the safety and/or integrity of our users, employees, third parties, members of the public, and/or our Services.
• Prevent, detect, investigate, and respond to fraud, unauthorized access/use of the Services, breaches of terms and policies, or other wrongful behavior.
• Detect and prevent fraud or other criminal activities; and
• Carry out any other purpose for which the information was collected.

Consumers

We may use your information to: 

• Collect debts.
• Process payments. 
• Communicate with you.
• Compare information for accuracy and verify our records. 
• Comply with our legal obligations or as permitted by law.
• Protect the safety and/or integrity of our users, employees, third parties, members of the public, and/or our Services.
• Prevent, detect, investigate, and respond to fraud, unauthorized access/use of the Services, breaches of terms and policies, or other wrongful behavior.
• Detect and prevent fraud or other criminal activities; and
• Carry out any other purpose for which the information was collected.

Whether you are a Client or Customer, we may combine information that we collect from you through the Services with information that we obtain from other sources.  We may also aggregate and/or de-identify information collected through the Services. We may use and disclose de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes.

4. When We Disclose Your Information

We may disclose your information for the following reasons:

• We may disclose your information to employees, vendors, consultants, and other service providers who need access to such information to carry out work or perform services on our behalf, such as those who assist in debt collection or provide data storage, payment, technology support and services, customer service, analytics, fraud prevention, legal services, and marketing services. 
• We may disclose your information to our affiliates, as permitted by law.
• We may disclose your information to credit reporting agencies, as permitted/required by law.
• We may disclose your information to our business partners, as permitted by law.
• We may need to disclose or provide access to information if CB1 has a good faith belief that such action is necessary to (i) comply with the law; (ii) comply with legal processes or governmental requests; (iii) prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of our website or our network; and/or (iv) to protect the rights, property, safety and security of CB1, our employees, our users, and/or the public.
• We may disclose your information if we believe your actions are inconsistent with our policies or agreements with you.
• We may disclose your information in connection with, or during negotiations of, any merger, acquisition, sale of assets or any business, other change of control transaction or financing; between any future parent, subsidiary, and/or affiliated company.
• We may also disclose your information as otherwise permitted or required by law or as authorized by you. 

5. Analytics 

We may use third-party web analytics services on the Services, such as those of Google Analytics. These service providers use the sort of technology described in the “Information we collect automatically” section above to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Service. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on.

Do Not Track

CB1 and the third parties who assist in operating the Services do not respond differently or limit their practices under the terms of this policy when you access those online services with a browser that uses a do not track signal.

6. Third Party Websites

CB1 may maintain links to other websites or services and other websites may maintain links to the Services. This Privacy Policy applies only to the Services and not to other websites or services accessible from CB1 or that you use to access CB1, each of which may have privacy policies materially different from this Privacy Policy. If you visit other websites or use other services, CB1is not responsible for the privacy practices or content of those sites. It is your responsibility to review the privacy policies of non-CB1websites and service to confirm that you understand and agree with them.

7. Text Messaging

By providing us with your mobile number and opting-in, you (a) give CB1 permission to send you account-related text messages, like payment reminders and notifications in conjunction with the services you have requested, and (b) agree you have ownership rights or permission to use the number given to us.  The number of messages will vary by account.  Message and data rates may apply. If your handset does not support MMS, any MMS’S messages sent may be delivered as SMS messages.  Wireless carriers are not liable for undelivered or delayed messages.

To opt-out of text messages, text STOP to any text message we send you. An opt-out confirmation message will be sent back to you.  You acknowledge that our text message platform may not recognize and respond to unsubscribe requests that do not include the STOP keyword command and agree that CB1 and our service providers will have no liability for failing to honor such requests. If you unsubscribe from one of our text message programs, you may continue to receive text messages from CB1 through any other programs you have joined until you separately unsubscribe from those programs.  

To request support, text HELP to any text message we send you or email us at privacy@cb1collections.com.

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.

8. Your Choices

• Account Information: You may update, correct, or modify information about you at any time by emailing us at privacy@cb1collections.com 
• Limit Sharing: in some cases, you may be able to limit the sharing of your information with affiliates and nonaffiliates to market to you.  To exercise this right, please contact us at privacy@cb1collections.com 
• Cookies: Most web browsers are set to accept Cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. The method for disabling Cookies may vary by device and browser, but can usually be found in your device or browser preferences or security settings. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Services. 
• Google Analytics: To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on.
• Promotional Communications: You may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at privacy@cb1collections.com . If you choose to opt out, we will still send you non-promotional communications, such as those about your Account or our ongoing business relations.
• Text messages:  For information on how to opt of text messages, please see Section 7 above.

9. Data Security

We maintain administrative, technical, and physical safeguards that are designed to protect the privacy and security of personal information. However, the Internet is not a fully secure environment, and we cannot ensure or warranty the security of any information transmitted to or generated by CB1 in connection with the Services or any other service offered by CB1. You play a critical role in protecting your information by maintaining up-to-date computer security protections. Steps you take to ensure the security of your computer, computer passwords, or other personal identifier authentication mechanisms are key components of the protection of your personal information. You agree that you are responsible for any additional verification procedures and security you deem necessary.

10. Personal Information of Children

The Services and CB1’s other services are not directed to children under the age of 13 (“Child”).  We do not knowingly solicit or collect personal information about Children. If you are a parent or guardian and you learn that your Child has provided us with personal information, please contact us. If we discover that a Child has provided us with personal information, we will delete such information from our servers as required by applicable law.

11. Notice to Persons Located Outside the United States

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world.  Your information may be transferred for processing and storage by CB1 and our affiliates and third parties.  If you do not want your information to leave your jurisdiction, do not provide the information to us. By providing information to us, you explicitly consent to the transfer of your information to the United States.

12. Notice to California Residents – Shine the Light

Under California Civil Code Section 1798.83 (also known as the “Shine the Light” law), users who are residents of California may request information regarding the disclosure of our personal information by us to third parties for the third parties’ direct marketing purposes.  We do not disclose your information to third parties for these purposes. 

13. Notice to Nevada Residents

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration to another person. “Personally identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.

We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting us using the information in the “Contact Us” section below. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

14. Changes to the Privacy Policy

We may change this Policy to reflect changes in the law, our information practices, or the features of the Services. At the top of our Policy, we will indicate the date of the most recent update. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Policy.

15. Contact Us 

If you have questions or concerns regarding this Privacy Policy, you should contact us by email at privacy@cb1collections.com