Privacy Policy

SCOPE:
This policy defines how Allied Collection Services Inc., (“ACSI”) will collect, use, share and protect consumer personal information in accordance with Graham Leach Bliley Act also known as the Financial Services Modernization Act of 1999.
 
POLICY:
The purpose of this policy is to ensure compliance with Graham Leach Bliley Act also known as the Financial Services Modernization Act of 1999.
See Exhibit A, B and C
 
DEPARTMENTS RESPONSIBLE FOR IMPLEMENTATION:
Compliance Department
 
RESPONSIBILITIES:

• The Chief Compliance Officer or his designee is directly responsible for developing, implementing, and establishing procedures implemented by this policy and shall ensure the compliance department is responsible for auditing and monitoring this policy.
• Data Management is responsible for all onboarding and scrubbing practices as defined and implemented by this policy.

DEFINITIONS:
N/A
 
REFERENCE DOCUMENTS:

• ACSI-MP: 101.1 Management Review
• ACSI-MP: 1601.1 Training

ACSI Website Privacy Policy
This notice discloses the privacy practices for www.acsnv.com, and applies solely to information collected by this web site.
 
Pursuant to the Fair Debt Collection Practices Act (FDCPA) this communication is from a debt collector; any information obtained by Allied Collection Services Inc. (ACSI) including information obtained via our website, may be used for this purpose.
 
What personally identifiable information is collected from you through the web site, how it is used and with whom it may be shared. What choices are available to you regarding the use of your data. The security procedures in place to protect the misuse of your information. How you can correct any inaccuracies in the information.
 
Information: (Collection, Use and Sharing)
We are the sole owners of the information collected on this site. We only have access to/collect information that you voluntarily give us via email or other direct contacts from you. We will not sell or rent this information to anyone. We may use your information to respond to you, regarding the reason you contacted us. We will not share your information with any third party outside of our organization unless such disclosure is required as part of our day to day business activities, and/or as necessary to conduct a required state, federal or other required investigation, fulfill your request, e.g. to mail you information or to respond to a communication initiated by you.
 
Unless you ask us not to, we may contact you via email to respond to a communication initiated by you, and/or provide important account information (i.e.; Notice of future payment activity) or changes to this privacy policy.
 
What Does ACSI Do with Your Personal Information?

Our Privacy Policy
Federal law requires us to tell you how we collect, use, share, and protect your personal information. Federal law also limits how we can use your personal information. Protecting the privacy and security of consumers’ personal information is very important to us. Please read this notice carefully to understand what we do with the personal information we collect both online and offline.
 
ACSI may collect personal information about you when you contact us regarding a debt, and/or to help you with a problem, including but not limited to other persons you have authorized to discuss information about you; issues submitted via the Consumer Financial Protection Bureau (CFPB), Better Business Bureau BBB), A State Attorney General’s Office (SAG), and/or via your Attorney.
 
We collect and use only the information necessary to respond to your concerns, conduct investigations and/or as related to the collection of a debt. In most instances, we collect minimal personal information, such as name, address, telephone number, or email address. In limited cases, depending on the nature of your request we also may collect other personal information such as your social security number, account numbers, or health information. This information may also be used to verify your identity, and/or verify your account information, or to provide information about to as required by law, or necessary to furnish information about you to a credit reporting agency.
 
When do we collect personal information?

• When you contact us to verify your identity, order documents, obtain redress, or as necessary for debt collection to notify our client, or to investigate or respond to possible consumer fraud or identity theft.
• When we contact you to verify your identity, as necessary for debt collection efforts; to provide information in response a dispute, complaint.
• When we contact others to collect information about you.

Where does your information go?
ACSI may share the least amount of information necessary to comply with State and Federal Law; to conduct collection efforts and/or complete our investigative duties including but not limited to the Fair Debt Collection Practices Act (FDCPA), the Fair and Accurate Credit Reporting Act (FCRA) and the Dodd-Frank Act.
 
To Our Vendors
Our contractors/vendors may use your information when they perform certain services, such as credit reporting and/or to obtain or provide investigative reports.
 
To government agencies (federal, state, local)
We work with various state, federal and local government agencies to investigate and/or respond to consumer disputes, complaints, or to follow up on ID theft/fraud investigations and reports.
 
To others outside government…
We may respond to public comments, complaints and/or disputes that you have initiated that require we publish or release information about you, including names, state of residence, and other non-confidential information.
 
We may furnish and provide information about you to national credit reporting agencies regarding your account, including but not limited to information necessary to respond to or satisfy our duty under applicable state or federal law regarding consumer fraud, ID theft.
 
We may provide information to businesses or individuals in response to court orders, subpoenas, discovery requests, or Freedom of Information Act requests, or to resolve complaints.
 
We may use third-party services on our website to assist in communicating or interacting with the public.
 
Additional Privacy-Related Information
When you visit our website http://ww.goacsi.com/ we may track information to administer the site and or analyze its usage, including but not limited to:

• Your Internet protocol address.
• The kind of browser or computer you use.
• Number of links you click within the site.
• State or country from which you accessed the site.
• Date and time of your visit.
• Name of your Internet service provider.
• Web page you linked to our site from.
• Pages you viewed on the site.

Use of Cookies:
We may use cookies to store information, such as your personal preferences when you visit our website. This could include only showing you a popup once in your visit, or the ability to login to some of our features, such as accessing required disclosures, obtaining or submitting information.
 
Personal Identification Information (PII)
We will not disclose personally identifiable information we collect from you to third parties without your permission except to the extent necessary including:

• As authorized by law.
• To protect ourselves from liability,
• To respond to legal process or comply with applicable state or federal law, or
• In connection with a merger or acquisition of the company.

Changes to this Statement
ACSI reserves the right to update this privacy statement. When we do, we will also revise the “updated” date at the bottom of this Privacy Policy. We encourage you to periodically review this privacy statement to stay informed about how we are helping to protect the personal information we collect. Your use of service constitutes your agreement to this privacy statement and any updates.
 
California Privacy Rights:
If you are a California resident, you may ask us to refrain from sharing your personal information with our affiliates and other third parties for marketing purposes. Please tell us your preferences by contacting us via email at CCO@acsnv.com or by postal mail at the following address:
 
Questions or Complaints About This Privacy Policy:
 
Write to the ACSI Chief Compliance Officer:

 
Questions About Identity Theft & Online Issues:

• Visit ftc.gov/idtheft to learn about the crime of identity theft, including detailed information to help you deter, detect, and defend against it.
• Visit OnGuardOnline to learn how to be on guard against Internet fraud, secure your computer, and protect your personal information.

Your Access to and Control Over Information
You may opt-out of any future contacts from us at any time. You can do the following at any time by contacting us via the email address or phone number given on our website:

• See what data we have about you, if any.
• Change/correct any data we have about you.
• Have us delete any data we have about you.
• Express any concern you have about our use of your data.

 
Security & Compliance
ACSI is PCI-DCC level 1 Certified and take significant precautions to protect your information, including but not limited to the Department of Human Services, Health Insurance Portability Act (HIPAA) as limited as and or as permitted as a Business Associate of a Covered Entity.
 
When you submit sensitive information via the website, your information is protected both online and offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.
 
Links:
This web site may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information. If you feel that we are not abiding by this privacy policy, you should contact us immediately.