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:
- On our website.
- In e-mail, text and other electronic messages between you and our website.
It does not apply to information collected by or through:
- Any other means including on any other website operated by any third party; or
- Any third party, including through any application or content that may link to or be accessible from, or on, our website.
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 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 usage details, IP addresses and information collected through other tracking technologies.
- From third parties we contract with to provide services on our behalf.
We may also collect information about you offline if your provide it to us by mail, fax, or telephone.
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 will never 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:
- Calling us at (855) 342-6567
- Emailing us at email@example.com
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.
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 or you provide as described in this Policy:
- To contractors, service providers, and other third parties we use to support our business, such as insurers, information source, payment processing, and communication service providers, 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.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Phoenix or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. Phoenix 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.
Phoenix 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.
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 855-342-6567.
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.
- De-identified 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, including: name, DOB, address, gender, account number, previous payment and other financial information, email address, insurance information, records about services or goods purchased, 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 also may collect additional categories of personal information you provide directly to us or our vendors.
2. How Your Personal Information Is Collected
We collect most of this personal information from our 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 records or court records);
- From our vendors (e.g., call analytics, skip-tracing, payment processing, mailing, and other vendors)
3. 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, SSN, 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 and will not sell your personal information under the CCPA.
4. 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 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 CCPA 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:
- 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;
- Re-identify 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 CCPA or applicable exception applies.
5. 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 we collected from you and retained, subject to certain exceptions.
We may deny your deletion request if retaining the information is necessary to:
- Complete the transaction for which the personal information was collected, provide a good or service requested by you, otherwise perform a contract between you and us or our client, or as reasonably anticipated within the context of your ongoing relationship with us or our client.
- 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 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 CCPA or applicable exception applies.
California residents may submit verifiable requests for information or deletion described herein by calling us at (855) 342-6567 or e-mailing us at firstname.lastname@example.org.
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.
If you are seeking to make a verifiable request under the CCPA 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 CCPA 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 CCPA 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 CCPA request will be used solely for the purposes of verification.
Last modified: 8/15/2020