This Privacy Notice sets forth the information gathering, use, and dissemination practices of Transworld Systems, Inc. (“TSI”) in connection with the website located at www.tsico.com (the “Site”). This Privacy Notice addresses TSI’s practices regarding information collected only directly through or from its Site – it does not address or govern any information gathering, use, or dissemination practices related to information collected other than directly through or from its Site, including, without limitation, from or via telephone, facsimile, postal mail, personal delivery, or other or additional offline means or media.
The Site is not intended for children under the age of 18. It does not knowingly collect personal information online from visitors in this age group.
IMPORTANT DISCLOSURE ABOUT THE FDCPA: Nothing in this Site Privacy Notice is intended to contradict your rights under the Fair Debt Collection Practices Act. TSI will not disclose any information to third parties that is otherwise prohibited by the FDCPA.
TSI collects, uses, and stores information on the domain you use to access its Site, the Internet address of the site from which you linked directly to its Site, and the date and time of your visit to its Site. This information may be used to measure the number of visitors to the various pages on the TSI Site, to help make improvements to the information contained on the site, and to better serve site visitors through special marketing and service programs, among others. TSI also collects, uses, and stores the e-mail addresses of users that communicate with TSI via e-mail, information knowingly provided by Site users, and information regarding which Site pages users’ access. TSI may also use Internet cookies and other identifiers or methods of web analysis (such as Google Analytics) to gather, store, and track certain information related to your visit to and activity on the Site. If you are uncomfortable with the idea of your information being used in this way, most computer systems and web browsers offer privacy settings and options, such as disabling cookies or opting for “Do Not Track” features. TSI does not override these settings or options, and encourages you to use them to enhance your choices and personalize your experiences. However, in order to access certain content, features, services, products or benefits on the Site, you may be required to provide TSI with certain information, including some types of personally identifying information such as your email, your address, and your phone number. If you do not wish to provide such information through the Site or if you opt to utilize the aforementioned privacy features of your computer system or web browser, you may be unable to obtain certain content, features, services, products or benefits of the Site.
Personal information contained in e-mail sent by individuals may be used by TSI to answer questions, follow-up on suggestions or complaints, process requests or transactions, or improve the level of service TSI provides.
TSI may share personally identifiable information obtained on its Site with any company or marketing group internal to TSI or its affiliates. Except as provided below, TSI does not share any personally identifiable information obtained on its Site with or sell information obtained on this Site to any company or marketing group external to TSI and its affiliates. TSI may, however, share aggregate information with other persons or entities for purposes determined by TSI to be appropriate.
TSI may disclose identifiable information (i) to another entity with which TSI 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 (iii) to a third party if determined by TSI in its sole judgment that such disclosure is appropriate to protect the life, health, or property of TSI or any other person or entity. (The foregoing is not intended to obviate or displace any legal obligations or duties applicable to TSI.) Your personal information and data, whether personally identifying or not, may also be provided to third parties that contract with TSI to provide products, information or other services that TSI believes that visitors to the Site may be interested in obtaining. While TSI may undertake efforts to see that any third party to which TSI discloses personal information is under an obligation to use the personal information solely for the purposes for which the information was disclosed such third parties are independent third parties over which TSI exercises no control. TSI is not responsible for, and will not be liable for, the conduct, actions, omissions, or information handling or dissemination practices of third parties.
Except as necessary for TSI to provide the services, information, or products requested by a Site user, or except for the disclosures identified in the preceding paragraph, the user may opt out of having his or her personally identifiable information, which has been voluntarily provided to TSI through or from its Site, prospectively retained by TSI, used by TSI for secondary purposes, or disclosed by TSI to third parties, by contacting TSI via postal mail at the address set out below or at the following e-mail address: TSI-Marketing@tsico.com. This provision does not apply to collection of the type of web browser used to visit the Site or to information provided or collected that does not meet the description hereunder.
While TSI may undertake efforts to see that another party to which TSI shares personal information is under a contractual obligation to use the personal information solely for the purposes for which the information was disclosed by TSI, TSI exercises no control over such parties and TSI is not responsible for their conduct, actions, omissions, or information handling or dissemination practices.
California Civil Code Section 1798.83 (also known as the “Shine The Light” law) permits users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request by mail to the address below or to the following email address: TSI-Marketing@tsico.com.
E-mail posted or sent through this Site may not be secure against interception by unauthorized individuals. To protect against interception by unauthorized individuals, we will not respond to e-mail requests concerning accounts placed for collection. Therefore, if you are communicating with TSI regarding a debt that has been placed for collection with Transworld Systems Inc., all correspondence regarding that account should be sent by U.S. Postal Service. Be sure to include your name, your mailing address, the TSI account number, creditor name, and creditor account number so that we may process your inquiry and respond promptly. Without complete information, we will be unable to respond to your request.
The address for mailing inquiries is:
P.O. Box 15618
Wilmington, DE 19850
TSI has implemented physical, electronic, and procedural security safeguards to protect against the unauthorized release of or access to personal information. Additionally, to further safeguard this information, our employees are asked to agree to TSI’s Standards of Conduct and Work Rules as well as Confidentiality Agreements, and are subject to disciplinary action up to and including termination of employment if they fail to follow signed agreements. However, the confidentiality of any communication or material transmitted to or from TSI via the Site or via email cannot be, and is not, guaranteed. You acknowledge that the technical processing and transmission of the Site’s content may be transferred unencrypted and involve: (a) transmissions over various networks; and (b) changes to conform and adapt to technical requirements of connecting networks or devices. Accordingly, TSI is not responsible for the security of information transmitted via the Internet.
IMPORTANT PRIVACY CHOICES FOR CONSUMERS
You have the right to control whether we share some of your personal information. Please read the following information carefully before you make your choices below.
We will collect the IP Address for internal security and other proprietary purposes. We will do so even if you have included a Do Not Track request. We do not release this data outside of our corporate environment nor utilize this data other than for internal purposes.
You have the following rights to restrict the sharing of personal and financial information with our affiliates (companies we own or control) and outside companies that we do business with. Nothing in this form prohibits the sharing of information necessary for us to follow the law, as permitted by law, or to give you the best service on your accounts with us. This includes sending you information about some other products or services.
Restrict Information Sharing With Companies We Own or Control (Affiliates): Unless you contact us and state otherwise, we may share personal and financial information about you with our affiliated companies.
Restrict Information Sharing With Other Companies We Do Business With To Provide Financial Products And Services: Unless you contact us and state otherwise, we may share personal and financial information about you with outside companies we contract with to provide financial products and services.
TIME SENSITIVE REPLY
You may make your privacy choice(s) at any time. Your choice(s) will remain unless you state otherwise. However, if we do not hear from you we may share some of your information with affiliated companies and other companies with whom we have contracts to provide products and services.
To exercise your choice to restrict information sharing, please contact us by doing one of the following:
- Call us toll free: (877) 282-1250
- Or, you may submit them online (your privacy preferences) using the Questions/Complaints Inquiry Form on our Consumer Support
- Or, you may print, complete and send back the form below to us at:
PO Box 15618
Wilmington, DE 19850
Please print a copy of this form and complete it in pen and printed handwriting. Mail it to the address noted above. You may want to make a copy for your records.
- Information We Collect About You
We may collect and use personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be directly or indirectly linked, with a consumer, device, or household (“personal information”).
Personal Information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, such as (but not limited to) information governed by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the California Confidentiality of Medical Information Act (“CMIA”), the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”), California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994 (“DPPA”).
We regularly collect (and have collected in the past 12 months) several types of personal information about individuals offline regarding accounts we service for other entities, including: name, DOB, address, gender, account number, payment and other financial information, email address, insurance information, Social Security Number, employment information, telephone number, IP address, military or veteran status, audio information, username, publicly available information, and information collected or shared pursuant to HIPAA, CMIA, FIPA, GLBA, FCRA, DPPA, and/or other applicable privacy laws. We also may collect additional categories of personal information users provide directly to us, our clients, or our vendors.
- How Your Personal Information is Collected
We collect most of this personal information from our creditor clients or from you or your authorized representative if you provide it to us. However, we may also collect information:
- From publicly accessible sources (e.g., property or other government records);
- From our vendors (e.g., call analytics, information source, skip-tracing, payment processing, mailing, and other vendors)
- Why We Use or Disclose Your Personal Information
We regularly use or disclose personal information for one or more of the following business purposes:
- Fulfill 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.
- Perform services on behalf of a business or service provider, including maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, processing payments, providing analytic services, or providing similar services on behalf of the business or service provider
- Provide you with information or services that you request from us
- Auditing related to consumer interactions
- 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
- Short-term, transient use, where the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction
- Undertaking activities to verify or maintain the quality of a service or device that is owned, made by or for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, made by or for, or controlled by us
- Respond to law enforcement requests and as required by applicable law or court order
- As 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 purposes without providing you notice.
We regularly disclose (and have disclosed in the past 12 months) several types of personal information about individuals for one or more business purposes, including: name, DOB, address, gender, account number, previous payment and other financial information, email address, insurance information, Social Security Number, employment information, telephone number, IP address, military or veteran status, audio information, username, and information collected or shared pursuant to HIPAA, CMIA, FIPA, GLBA, FCRA, DPPA, and/or other applicable privacy laws.
We have not sold your personal information over the last 12 months and will not sell your personal information under the CCPA.
- Verifiable Consumer Requests for Information
Upon verification of identity, California residents may in some cases request that a business:
- Disclose the categories of personal information the business collected about the consumer;
- Disclose the categories of sources from which the personal information is collected
- Disclose the categories of personal information that the business sold about the consumer;
- Disclose the categories of personal information that the business disclosed about the consumer for a business purpose;
- Disclose the categories of third parties with whom the business shares personal information
- Disclose specific pieces of personal information the business has collected about the consumer
- Disclose any financial incentives offered by the business for collection, sale, or deletion of personal information
Businesses that provide information requested pursuant to the CCPA must provide such information in a readily useable format and allow consumers to transmit the information from one entity to another without hindrance.
A business may charge a different price or rate, or provide a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to you by your personal information.
Please note that we are not required to:
- Carry out information access requests we receive from you if acting as a service provider to another entity regarding such information
- 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 requested information if a CCPA or applicable exception applies.
- Right to Request Deletion of Personal Information
Upon verification of identity, California residents may in some cases request that a business delete personal information collected from them, subject to certain exceptions.
We may deny your deletion request if we are acting in the role of a service provider to another business regarding the applicable personal information. If we deny your request on that basis, we will generally refer you to the relevant business. In addition, we may deny your deletion request if retaining the information is necessary for us or our client to:
- Complete the transaction for which the personal information was collected, provide a good or service requested by you, as reasonably anticipated within the context of your relationship with the relevant business, or otherwise perform a contract between you and the business.
- 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 the relevant business.
- Comply with a legal obligation.
- Otherwise use your personal information internally in a lawful manner that is compatible with the context in which you provided the information; or
- If another CCPA or applicable exception applies.
California residents may obtain more information about verifiable requests pursuant to the CCPA by contacting us by completing a web form at https://www.tsico.com/consumer-support or calling us at toll-free number 1-866-280-9103.
- Verifying Your Identity If You Submit CCPA Requests
If you choose to contact us directly via the designated methods described above to exercise your CCPA rights, you will need to:
- Provide enough information to reasonably identify you [(e.g., your full name, account number if applicable, and potentially other identifying information]; and
- Describe your request with sufficient detail to allow us to properly process and respond to your request.
In addition to the exceptions described in this Notice, we are not obligated to make an information disclosure or carry out a deletion request pursuant to the CCPA if we cannot sufficiently verify the identity of the requestor or the requestor’s authorized representative if applicable.
Any personal information we collect from you in order to verify your identity in connection with your CCPA request will be used solely for the purposes of verification.
Dated: January 6, 2020
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