Privacy Notice for California Residents
This Privacy Notice applies only to visitors, users, and others who reside in the State of California, and is provided pursuant to the California Consumer Privacy Act (CCPA). This Privacy Notice supplements our Privacy Policy.
Personal Information We Collect
We have collected the following categories of personal information including sensitive personal information as those terms are defined in the CCPA, in the preceding twelve (12) months from consumers:
- Personal identifiers such as name, address, email address, SSN, driver’s license or state identification card, passport number, bank account, financial or personal history information, or other similar identifiers, which we obtain from the consumer’s creditor, credit reporting agencies, skip trace sources, and from consumers;
- Information described in California Customer Records Act, such as name, signature, address, telephone number, education, employment, employment history, and payment information;
- Characteristics of protected classifications under California or federal law;
- Commercial information;
- Internet or other network activity, such as IP (Internet Protocol) addresses of computers used to visit this site preserved in the system, and other information such as email addresses, browser types, operating systems, and the URL addresses of sites clicked to and from this site, or if a consumer visits a payment portal;
- Geolocation data;
- Audio recordings;
- Professional or employment-related information, which we obtain from the consumer’s creditor, credit reporting agencies, and other skip trace sources;
- Educational information, which we obtain from the consumer’s creditor; and
- Inferences drawn from other personal information.
We will not collect additional categories of or use the personal information collected for materially different, unrelated, or incompatible purposes without providing you notice.
The categories of sources from which personal information is collected are:
- Directly and indirectly from business clients and consumer creditors, and their agents, such as from information they provide to us in order for us to provide services;
- From consumers with whom we communicate;
- From service providers and vendors, who provide goods or services;
- Directly or indirectly through the Internet, websites and payment portals, through consumer visits to such sites or submissions; and
- From job applicants and employees.
The business or commercial purposes for collecting personal information including sensitive personal information as those terms are defined in the CCPA, are:
- For debt collection;
- For regulatory compliance;
- To comply with contractual or legal requirements under state and federal laws;
- To ensure data integrity; and
- For employment purposes, such as in connection with job applicants and employees.
The categories of third parties to whom personal information may be disclosed are:
- Businesses and creditors, and their agents;
- Service Providers, Contractors and vendors;
- Federal, state and local regulators, courts, and other governmental agencies, as necessary; and
- Professional and legal advisors.
You have the right to request the specific pieces of personal information collected about you.
The categories of personal information including sensitive personal information as those terms are defined in the CCPA, are retained until the business purpose for which they have been collected is completed, or pursuant to contractual or business requirements, or as required pursuant to applicable laws.
Disclosure of Personal Information for a Business Purpose
We do not sell or share your personal information as those terms are defined under the CCPA. We do not knowingly sell or share any personal information of anyone under age 18.
We engage certain parties to perform functions and provide services to us for a business purpose. We may share your personal information with these parties, but only to the extent necessary to perform these functions or provide such services. We require that all personal information we disclose to a recipient be maintained in a secure and confidential manner.
In the preceding twelve (12) months, the categories of personal information that we disclosed for a business purpose are:
- Personal identifiers such as name, address, email address, SSN, driver’s license or state identification card, passport number, bank account, financial or personal history information, or other similar identifiers, which we obtain from the consumer’s creditor, credit reporting agencies, skip trace sources, and from consumers;
- Information described in California Customer Records Act, such as name, signature, address, telephone number, education, employment, employment history, and payment information;
- Characteristics of protected classifications under California or federal law;
- Commercial information;
- Geolocation data; and
- Audio recordings.
We do not disclose sensitive personal information for purposes other than as provided in this notice and as authorized pursuant to the CCPA.
Your Deletion 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 or Contractors 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 a Service Provider or Contractor to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested or authorized, take actions reasonably anticipated within the context of an ongoing business relationship with you, or otherwise perform a contract with you;
- Help ensure security and integrity to the extent the use of personal information is reasonably necessary and proportionate for those purposes;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, 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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which the information was provided;
- Comply with a legal obligation; and/or
- An exemption or exception to the requirement to delete personal information applies.
If we deny your request because all of the information collected or maintained about you has been pursuant to our role as a Service Provider or Contractor, we will provide you with the contact information of the Business on whose behalf we collect or maintain the information.
We will retain personal information in an identifiable form only for the period necessary to fulfill the purposes of the processing and subject to our legitimate business needs, unless a longer retention period is required or permitted by law.
Your Right to Correct
You have the right to request that we correct inaccurate personal information it maintains about you. Once we receive and confirm your verifiable consumer request, we will use commercially reasonable efforts to correct (and direct our Service Providers or Contractors to correct), your personal information unless an exception applies.
Your Access Rights
You have the right to request that we disclose the following information to you about our collection of personal information in the preceding twelve (12) months:
- The categories of personal information we collected;
- The categories of sources from which personal information was collected;
- Our business or commercial purpose for collecting personal information;
- The categories of personal information that we disclosed for a business purpose;
- The categories of third parties to whom personal information was disclosed for a business purpose; and/or
- The specific pieces of personal information we collected or disclosed.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services;
- Charge your different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of goods or services;
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services; nor
- Retaliate against you if you are an employee, applicant for employment, or independent contractor.
Exercising Correction, Access and Deletion Rights; Data Portability; Authorized Agents
To exercise your rights to correction, access and deletion described above, or to make a data portability request, you may submit a verifiable consumer request to us in the following ways:
- Calling us at 800-264-6850
- Emailing us at [email protected]
- Mailing address: Commercial Services Group, Inc., Attn: Privacy Inquiry, 2001 Newmarket Drive, Louisville, KY 40222
Only you, or an authorized agent on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to requests or provide personal information if we cannot verify your identity or an authorized agent’s authority to make the request, and confirm the personal information relates to you.
We will only use personal information in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
Response Timing and Format
We will respond to a verifiable consumer request within forty-five (45) days of receiving it. If additional time is required, we will inform you of the reason and extension period (an additional 45 days), in writing. Any disclosures we provide will cover just the twelve (12) month period preceding receipt of the verifiable request. Our response will also explain the reasons we cannot comply with a request, if applicable. We will 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 the cost before completing your request.
Contact Information
If you have any questions about this Privacy Policy, the Privacy Notice for California Residents, the ways we collect and use your information as explained here, your choices and rights regarding such use, exercising your rights, or for consumers with a disability who would like to access this information in an alternate format, you may contact us by:
- Emailing us at [email protected]
- Mailing address: Commercial Services Group, Inc., Attn: Privacy Inquiry, 2001 Newmarket Drive, Louisville, KY 40222