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Privacy Policy

Privacy Policy

This Privacy Notice sets forth the information gathering, use, and dissemination practices of Transworld Systems Inc. (“TSI”). 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.

This Privacy Policy is incorporated into TSI’s Terms and Conditions for the Site, which must be reviewed and accepted by you.

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.

The Site may also contain links to third party websites, for the convenience of users in locating information, products, or services that may be of interest. If you access a third-party website from a link on this Site, any information you disclose on that website is not subject to this Privacy Policy. It is possible that these links may be used by third parties or others to collect personal or other information about you. TSI is not responsible for the privacy practices of such websites, advertisers, or third parties or the content of such websites and it is your sole obligation to review and understand the privacy practices and policies of these other websites. TSI does not control these third parties’ use of cookies, collection of information, or how they manage such information. It is solely your obligation to review and understand the privacy practices and policies of these other websites, advertisers and any third parties. 

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.

YOUR RIGHTS

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.

YOUR CHOICES

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

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:

1. Call us toll free: (877) 282-1250

2. Or, you may submit them online (your privacy preferences) using the Questions/Complaints Inquiry Form on our Consumer Support

3. Or, you may print, complete and send back the form below to us at: PO Box 15618 Wilmington, DE 19850

Opt-Out Form

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.

TSI reserves the right at any time to modify, alter or update this Privacy Policy. Your use of the Site following any changes means that you agree to follow and be bound by the Privacy Policy as changed. Any change to this Privacy Policy shall be effective as to any visitor who has visited the Site before the change was made. It is the obligation of users visiting the Site before the change to learn of changes to the Privacy Policy since their last visit.

PRIVACY POLICY

Introduction

Transworld Systems Inc. (“TSI”) respects your privacy and is committed to protecting it through our compliance with this website privacy policy (“Policy”). Maintaining protection of the information entrusted to our care is of the utmost importance to TSI.

This Policy describes the types of information we may collect from you or that you may provide when you visit our website and our practices for collecting, using, protecting, and disclosing that information.

This Policy applies to information we collect or you submit to us through the TSI website.  This Policy does not apply to information collected by or through websites, applications, or content operated by any third party.

This Policy outlines our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you should not use our website. By accessing or using our website, you agree to this Policy. This Policy may change from time to time (see Changes to Our Privacy Policy section below). Your continued use of our website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

Information We Collect About You And How We Collect It

We collect several types of information from and about users of our website, including information:

  • by which you may be personally identified, including your name, e-mail address, or telephone number (“personal information”);
  • that is about you but individually does not identify you; and/or
  • about your internet connection, the equipment you use to access our website, and website usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the website. Information collected automatically may include, for example, usage details and IP addresses.
  • From third parties we contract with to provide services on our behalf.

Important Privacy Information for Consumers

You have the right to control whether we share some of your personal information. Please read the following information carefully.

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.

Important Information Regarding the Fair Debt Collection Practices Act

We do not disclose information to any party in violation of the Fair Debt Collection Practices Act.

Requesting Access or Changes to Your Information

You can make changes to personally identifiable information we collect from you by one of the following methods:


Information You Provide To Us

We collect information you provide to us on or through our website including:

  • Information that you provide by filling in forms on our website.
  • Records and copies of your correspondence (including e-mail addresses), if you contact us.

 

Usage Details, IP Addresses, Cookies, And Other Technologies

As you navigate through and interact with our website, we may automatically collect certain information about your equipment, browsing actions and patterns, including:

  • Details of your visits to our website, including traffic data, location data, logs and other communication data and the resources that you access and use on our website.
  • Information about your computer and internet connection, including your IP address, operating system and browser type.

The information we collect automatically is statistical data, and does not identify any individual.

There may be features that are developed in the future that may result in the collection of additional new information.

We do not allow third parties to collect personally identifiable information about a user’s online activities, over time and across different sites, services, and applications, when that user uses our site or service. 

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our website and its contents to you.
  • To provide you with information or services that you request from us.
  • To offer and fulfill our core business purposes.
  • To fulfill any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us or an owner or previous owner of an applicable account, including for billing and collection.
  • To notify you about changes to our website or any products or services we offer or provide though it.
  • To allow you to participate in interactive features on our website.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

 

Disclosure Of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect as described in this Policy:

  • To contractors, service providers, and other third parties we use to support our business, such as clients, insurers, information source vendors, and payment processors, who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law or legal process, including to respond to any government or regulatory request.
  • Pursuant to a merger, acquisition, or sale of all or a portion of TSI’s assets.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of TSI or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. TSI has implemented physical, electronic, and procedural security safeguards to protect against the unauthorized or unlawful release of or access to personal information, including any social security numbers. To further safeguard this information, access to sensitive information such as social security numbers is limited, and our employees must abide by standards of conduct and confidentiality agreements.

 

Changes To Our Privacy Policy

TSI may change, add, modify or remove portions of this Policy at any time, which shall become effective immediately upon posting on this page. The date the Policy was last revised is identified at the bottom of the page. It is your responsibility to review this Policy for any changes. By continuing to use our website, you agree to any changes in the Policy.

Contact Information

If you have any questions about our privacy protection practices or believe we have not adhered to this Policy, please contact us on our main phone number at 1-877-282-1250.

Changes of Ownership or Control of TSI

We may transfer, combine, merge, or sell all or part of our business to another entity or entities.  If such an event occurs, personal information TSI has collected or maintained may be transferred to a new controlling party or parties, who will be permitted to use your personal information under the terms of this Policy for the purposes for which you supplied it. 

CALIFORNIA RESIDENTS: PRIVACY POLICY NOTICE

This Privacy Policy Notice is intended for California residents pursuant to the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 (collectively “CPRA”), and supplements the information contained in the above Privacy Policy.  Any terms defined in the CPRA and applicable California regulations have the same meaning as used in this Privacy Policy Notice.  If you have a disability and want this Privacy Policy Notice provided in an alternative format, please call us as 1-877-282-1250 or write us at 500 Virginia Drive Suite 514, Fort Washington, PA 19034.  If you have questions about our Privacy Policy or practices, please call 1-877-282-1250.

 

  1. 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 CPRA’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 regarding accounts we service or purchase, including:

Category

Examples

Identifiers

Name, postal address, Internet Protocol address, email address, account number, Social Security number, or other similar identifiers

Categories listed in the California Customer Records statute, Cal. Civ. Code § 1798.80(e)

Name, signature, Social Security number, address, telephone number, education, employment, bank account number, credit card number, debit card number, or other financial information, medical information, or insurance information

Protected classifications under California or federal law

Age, gender, medical condition, disability, veteran or military status

Commercial information

Records of products or services purchased, obtained

Internet or other similar network activity

Information on a consumer’s interaction with our website(s) or  application(s)

Audio, electronic, visual or similar data

Call recordings

Professional or employment-related information

Current or past job history

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

Student financial information

Inferences drawn from personal information

To create a profile reflecting the consumer’s preferences, characteristics, aptitudes, or behavior

Sensitive personal information

A consumer’s social security number, driver’s license, state identification card, or passport number; a consumer’s account log-in in combination with any required security or access code, password, or credentials allowing access to the account

  1. How Your Personal Information is Collected

We collect most of this personal information from our creditor clients or from you or your authorized representative by telephone or written communications.  However, we may also collect information:

  • From publicly accessible sources (e.g., property or other government records);
  • From our service providers (e.g., call analytics, information source, skip-tracing, collections, payment processing, mailing, and other vendors)
  1. 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 CPRA.

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) the above listed categories of personal information for business purposes to one or more of the following categories of third parties: our creditor clients, our service providers (payment processing, mailing, collection, call analytics and other vendors), credit reporting agencies, regulatory and law enforcement agencies.

We do not sell or share your personal information under the CPRA. 

We do not use or disclose sensitive personal information for purposes other than those necessary to perform services reasonably expected by an average consumer; to help ensure security and integrity where use of the information is reasonably necessary and proportionate for this purpose; for short-term, transient use; for performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying customer information, processing payments, or providing similar services; for undertaking activities to verify or maintain the quality of our services, and to improve, upgrade, or enhance our services.

We retain each category of personal information or sensitive personal information no longer than is reasonably necessary for the purposes for which it was collected as stated in this privacy policy, unless extending the retention period is otherwise required or permitted by law.  Subject to this limitation, the retention period of each category of personal information or sensitive personal information is determined by considering the following: the time required to retain the information to fulfill our business purposes; the time applicable to maintaining corresponding transaction and business records; the time necessary to respond to consumer queries, complaints or lawsuits; data retention requirements of applicable laws or contracts; and applicable data retention policies as may be in place from time to time.

  1. 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

You have a right not to receive discriminatory treatment by a business for your exercise of CPRA privacy rights.  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.

For applicable personal information access and portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Please note that we are not required to:

  • Carry out information access requests we receive from you if acting as a service provider or contractor 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;
  • Provide the requested information disclosure to you more than twice in a 12-month period.
  • Provide the requested information 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; or
  • Provide the requested information disclosure if a CPRA or applicable exception applies.
  1. Right to Request Deletion of Personal Information

Upon verification of identity, California residents may in some cases request that a business delete personal information about you that the business collected from you and retained, 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 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.
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  • 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 CPRA or applicable exception applies.
  1. Right to Request Correction of Inaccurate Personal Information

Upon verification of identity, California residents may in some cases request a business that maintains inaccurate personal information about you correct that inaccurate personal information. We will use commercially reasonable efforts to correct the inaccurate personal information.

California residents may make verifiable requests to disclose, delete, or correct pursuant to the CPRA or obtain more information by contacting us at TSIcorrespondence@tsico.com , calling us at 1-877-282-1250, or mailing us at 500 Virginia Drive Suite 514, Fort Washington, PA 19034  

  1. Verifying Your Identity If You Submit CPRA Requests

If you choose to contact us directly via the designated methods described above to exercise your CPRA 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.

If seeking to make a verifiable request under the CPRA on behalf of someone else, we require enough information to reasonably identify the subject of the request (including name and other identifying information) and the subject’s written consent to make the CPRA request on his or her behalf, as consistent with applicable law.

We are not obligated to make an information disclosure or carry out a deletion request pursuant to the CPRA 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 in order to verify your identity in connection with your CPRA request will be used solely for the purposes of verification.

Last modified: 12/31/2023

COLORADO, CONNECTICUT, UTAH AND VIRGINIA RESIDENTS:

PRIVACY POLICY NOTICE

This Privacy Policy Notice is intended for Colorado, Connecticut, Utah and Virginia residents pursuant to the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act and the Virginia Consumer Data Protection Act, respectively. This policy supplements the information contained in the above Privacy Policy.  Any terms defined in these laws and related regulations have the same meaning as used in this Privacy Policy Notice. 

  1. Personal Data We Collect About You

We may process personal data 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 data”).

Personal data does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the scope of the above privacy laws, such as (but not limited to) information governed by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the Fair Credit Reporting Act (“FCRA”), and the Gramm-Leach-Bliley Act (“GLBA”).

We regularly process (and have processed in the past 12 months) several types of personal data about individuals regarding accounts we service or purchase, including:

Category

Examples

Identifiers

Name, signature, postal address, Internet Protocol address, email address, telephone number, account number, Social Security number, or other similar identifiers

Financial information

Bank account number, credit card number, debit card number, or other financial information; medical insurance information

Protected classifications

Age, gender, medical condition, disability, veteran or military status

Commercial information

Records of products or services purchased, obtained

Internet or other similar network activity

Information on a consumer’s interaction with our website(s) or  application(s)

Audio, electronic, visual or similar data

Call recordings

Professional, or employment-related information

Current or past job history

Non-public education information

Student financial information

Inferences drawn from personal information

To create a profile reflecting the consumer’s preferences, characteristics, aptitudes, or behavior

Personal information

A consumer’s social security number, driver’s license, state identification card, or passport number; a consumer’s account log-in in combination with any required security or access code, password, or credentials allowing access to the account

  1. Why We Process Your Personal Data

We regularly process personal data for one or more of the following business purposes:

  • Fulfill the reason you provided the information. For example, if you share your personal data 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 permitted by law.

We will not collect additional categories of personal data or use the personal data we collected for materially different purposes without providing you notice.

  1. Third Parties To Whom We Disclose Personal Data

We regularly disclose (and have disclosed in the past 12 months) the above listed categories of personal data for business purposes to one or more of the following categories of third parties: our creditor clients, our service providers (payment processing, mailing, collection, call analytics and other vendors), credit reporting agencies, regulatory and law enforcement agencies.

  1. We Do Not Sell Personal Data Or Engage In Targeted Advertising Or Profiling

We do not sell your personal data, process your personal data for targeted advertising, or process your personal data for automated decision-making including profiling in furtherance of decisions that produce legal or similarly significant effect on you.

 

  1. How To Request To Exercise Your Rights

Upon our verification of identity through commercially reasonable means, Colorado, Connecticut, Utah and Virginia residents may request to exercise one or more of the following rights:

  • To confirm whether or not we are processing your personal data and to access such personal data;
  • To delete personal data provided by or obtained about you;
  • To obtain a copy of your personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another company without hindrance, where the processing is carried out by automated means.

Additionally, upon our verification of identity through commercially reasonable means, Colorado, Connecticut, and Virginia residents may request to exercise the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes for processing the data.

You may request to exercise these rights by one of the following methods:

  • Calling us at 1-877-282-1250
  • Emailing us at TSIcorrespondence@tsico.com  
  • Mailing us at 500 Virginia Drive Suite 514, Fort Washington, PA 19034  

Colorado, Connecticut, Virginia residents may appeal our decision concerning your request by contacting us using any of the above methods, within 45 days of your receipt of our decision on your request, to advise of your appeal.

Last modified:  12/31/2023

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