Personal Information We Collect
Personal identification information is data that can be used to identify or contact you.
For Consumers in Collection
In order to provide and improve our services, we collect personal information. Most of the information we have is provided to us by the creditor and/or collected directly through the use of our services, emails, consumer account pages/payment portal reached through a link in an email or text message (our “Web Applications”), and phone calls.
Here are some examples of the types of personal information we may collect about consumers in collection:
- When an account is transferred to TrueAccord the creditor provides a variety of information including, but not limited to identifiers such as: full name, date of birth, phone number, address, email address, account number, original creditor, current creditor, balance, or payment history.
- We may collect sensitive personal information such as social security number, payment card information, or financial account information.
- We may collect any information that you provide to us directly whether you contact us by phone, email, SMS, Web Applications, or other channel. For example, when you access TrueAccord Web Applications and fill out a form or sign up for a payment plan and provide information such as your first and last name, email address, mailing address, phone number, credit card information and/or other personal identifying information.
- When you access TrueAccord emails or our Web Applications we may collect a variety of internet or other electronic network activity information and store it in log files, including, but not limited to Internet Protocol (IP) address, browser type and language, Internet service provider (ISP), type of computer, operating system, date/time stamp, user interface interaction data (such as, but not limited to, any mouse clicks or navigation on our emails and Web Applications), uniform resource locator (URL) information (showing where you came from or where you go to next), email open rates, credit card, or bank account information.
- When you access the trueaccord.com website, we may collect a variety of internet or other electronic network activity information and store it in log files, including, but not limited to Internet Protocol (IP) address, location of use, browser type and language, Internet service provider (ISP), type of computer, operating system, date/time stamp, user interface interaction data (such as, but not limited to, any mouse clicks or navigation on our emails and Web Applications), or uniform resource locator (URL) information (showing where you came from or where you go to next).
For Applicants, Current, and Former Employees
For Business Contacts
If you sign up for our newsletter, webinars, or any of our client-directed resources, we collect the information you provide on the forms or during the sign-up process. If we enter into a contract with your organization we collect the information you or your organization provides as one of the contacts for the business. Here are some examples of the types of personal information we may collect about our business contacts:
- If you sign up for a webinar, our marketing materials, or news digest using any of the forms on our website, we may collect personal information identifiers such as your name, employer, employer issued email, or work address.
- If you visit our website, we may collect internet or other electronic network activity information including, but not limited to Internet Protocol (IP) address, location of use, browser type and language, Internet service provider (ISP), type of computer, operating system, date/time stamp, user interface interaction data (such as, but not limited to, any mouse clicks or navigation on our emails and Web Applications), or uniform resource locator (URL) information (showing where you came from or where you go to next).
- If you become a client or a vendor we may collect personal information identifiers such as your name, employer, employer issued email address, phone number, or work address.
For Other Users of Website or Other Individuals With Whom We Interact
If you visit our website or otherwise interact with us, but you are not a consumer in collection, employee, or business contact, we may collect any of the categories of personal information described above which may vary depending on such interaction.
Using Personal Information
We use personal information depending on the category of consumer to provide our services.
For Consumers in Collection
We use consumer personal information to properly identify the specific consumers for whom we provide our services; to provide and improve our services; to analyze trends; to administer our Web Applications, learn about user behavior on our emails and Web Applications; to comply with state, federal and local laws; and to demonstrate compliance with those laws.
Here are some examples of how TrueAccord uses consumer personal information:
- We use personal information to send you communications about your account.
- We use your personal information to verify your identity. For example, when you contact our office you will be asked to provide your personal information so that we can verify your identity and account. We may ask you to provide your full name, address, email address, or other identifying information. You can always refuse to supply personal information, except that we may not be able to communicate if we are unable to verify your identity and/or account.
- We use personal information to process payments and other account activity you authorize.
- We use personal information to help us create, develop and improve our content and services, including through internal auditing and data analysis.
- We use personal information to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes.
- We use personal information as required to meet our regulatory and legal obligations.
In all of our consumer emails we use pixel tags. Depending on your email provider, pixel tags can enable us to tell us whether the email has been opened. If you prefer not to be tracked in this way, you should not open our emails. In most of our email messages, we use a “click-through URL” linked to our Web Applications and some linked to web pages on third party sites (see Third Party Websites below). We track this click-through data to help us determine interest in particular topics, measure the effectiveness of our customer communications, and send you emails or SMS (text messages) related to your activity on our website. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
For Applicants, Current, and Former Employees
We use potential employee information to evaluate candidates for employment, including but not limited to, verifying references, scheduling interviews, conducting a background check and other employment needs.
We use employee information for employment purposes, including, but not limited to, administering payroll and benefits plans, conducting background checks, professional licensing, executing on garnishment orders, and other employment needs.
For Business Contacts
We use business contact information to sell our services, buy your services, discuss the services we are receiving from your business, discuss the services we are providing to current clients and maintain our client and vendor relationships. Here are some examples of how TrueAccord uses business personal information:
- If you sign up for a webinar, request a demo, or fill out one of our forms, we may reach out to you to sell our services.
- If you are a client or vendor, we use your information to contact you about the contractual relationship between our companies.
Sources of Personal Information
If you are a consumer in debt collection, we received your personal information from the party placing your account with TrueAccord for services, such as the creditor, current creditor or servicer. We also receive information from you directly either through a phone call, email correspondence and/or through visits to our Web Applications. We also sometimes receive information from vendors who help us confirm the validity of our information as it relates to addresses, phone number, bankruptcy, and deceased information.
If you are a potential candidate, employee, or former employee, we may have received your personal information from you or from a recruiter or external website.
If you are a potential client and have expressed interest in our services or we think you have a legitimate business need for our services, we may have received your information from a lead-generation service or external website such as Zoominfo or LinkedIn.
If you are a potential, current or former vendor or client, we received your personal information from you or your company directly either through a phone call, email correspondence and/or the underlying contract between our organizations.
Disclosures of Personal Information
We only disclose personal information, such as identifiers, with a limited number of service providers and contractors (collectively “Vendors”) who help us provide our services, including, but not limited to, payment processing, mailing, information verification, managing and enhancing customer data, and improving our product and services. For employees, we disclose information with Vendors who help us with employee related services such as, but not limited to, payroll, benefits, and annual background checks requirements.
When we disclose information, we require those Vendors to handle it in accordance with relevant laws. If you so authorize, we also may disclose your email or other information you permit with our affiliates to provide information about other products and services.
When disclosing we only provide the minimum amount of information necessary for the particular Vendor to assist us in providing our services. Here are some examples of how TrueAccord discloses personal information:
- For payment processing, we disclose sensitive personal information, such as your credit card or bank information to the card-issuing bank to complete the payment you authorized.
- For content delivery, we disclose your email address, physical address, or phone number with the delivery service to deliver any communication, message, or requested account documents.
- For collectibility, we disclose name and address to ensure no bankruptcy, deceased, address or phone number changes have occurred since we received the account.
- For debt collection licensing, we disclose account information with state regulators conducting an audit pursuant to state or federal licensing statutes.
- We may be occasionally required by law enforcement or judicial authorities to provide information. We will disclose personal information pursuant to a court order, subpoena, or to cooperate with a law enforcement investigation.
We may also be required by law to provide your information to a local, state or federal government authorities or courts. We will only disclose information in these instances when there is a lawful basis or if disclosure is reasonably necessary to demonstrate compliance with the law.
In the event of a reorganization, merger or sale we may transfer any and all personal information we collect to the relevant third party.
We may also disclose any category of personal information to third parties for any of the following business purposes:
- To help ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes.
- For debugging to identify and repair errors that impair existing intended functionality.
- To perform services, including maintaining or servicing accounts, providing customer service, processing disputes, verifying customer information, processing payments, providing analytic services, or providing similar services.
- For internal research for technological development and demonstration.
We may disclose generic aggregated demographic information not linked to any personal information with our clients, potential clients, and federal, state and local regulators regarding visitors and users, and their interaction with our products and services.
No Sale, No Sharing
We do not sell personal information. We do not share personal information for cross-context behavioral advertising. We do not allow our vendors to sell this information or to share this information for cross-context behavioral advertising. We also do not sell or share the personal information of minors under 16 years of age without affirmative authorization.
Retention of Personal Information
Integrity and Personal Information Rights
You can help ensure that your contact information and preferences are accurate, complete, and up to date.
If you are a consumer, you can view your account information through any of the links in a TrueAccord email. For requests to know what information we have, correct inaccurate information, or delete information please email email@example.com or call 1-866-611-2731.
If you are a resident of California and an applicant, employee, or former employee, you can email requests to know what information we have, correct inaccurate information, or delete information to firstname.lastname@example.org. You may also send a letter with such requests to: TrueAccord, 16011 College Blvd, Suite 130, Lenexa, KS 66219 attention Privacy.
If you are a business contact, you can email requests to know what information we have, correct inaccurate information, or delete information to email@example.com. You may also send a letter with such requests to: TrueAccord, 16011 College Blvd, Suite 130, Lenexa, KS 66219 attention Privacy.
You will not receive discriminatory treatment or retaliation for the exercise of any of your rights.
When processing your request, we will ask you to verify your identity by providing us with your name, email address, telephone number or other piece of identifying information. You may also authorize an agent to act on your behalf. If you choose to have an authorized agent submit a request on your behalf, we will ask them to provide authorization forms executed by you, such as a power of attorney, demonstrating you authorized them to act on your behalf.
How We protect your information
TrueAccord is serious about data security. We recognize the importance of maintaining the security of our customers’ personal information and use reasonable security measures, including physical, administrative, and technical safeguards. These measures may include physical and technical security access controls or other safeguards, information security technologies and policies, procedures to help ensure the appropriate disposal of information, and training programs. For example, TrueAccord protects your personal information during transit using encryption such as Transport Layer Security (TLS) and at rest using encryption such as AES 256. When your personal information is stored by TrueAccord, we use computer systems with limited access housed in facilities using physical security measures.
Unfortunately, no data transmission over the internet or any wireless network can be guaranteed to be 100 percent secure. While we strive to protect your information, you acknowledge that by continued use of our website and Web Applications, there are certain security and privacy limitations beyond our control, and that the security, integrity, and privacy of any and all information exchanged between TrueAccord and our customers over the internet cannot be fully guaranteed from being viewed or tampered with in transit by a determined third party.
Third Party Websites
You may find links to third party websites on the TrueAccord website or Web Applications. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our website or Web Applications. In addition, these third party websites, including their content and links, may be constantly changing. These third party websites may have their own privacy policies and customer service policies. Browsing and interaction on any third party website is subject to that website’s own terms and policies.
How We Delete
We are obligated to maintain personal information for a variety of legal obligations.
If you are a consumer in collection, we are required to keep your data due to the underlying contractual relationship between you and the creditor. We are also required to keep the personal information for legal reasons for as long as the statute of limitations period lasts for the type of account in collections and for other statutory obligations which sometimes are longer (such as a state licensing statute requiring us to maintain records for a certain period of time or the statute of limitations for a consumer financial law).
If you are a job applicant, employee, or business contact, we may retain your information to provide you with services, to perform on a contract, for security, for our internal uses based on our business relationship, to comply with a legal obligation, or for other legitimate business purposes.
Once our legal obligation to keep your personal information has expired, we delete the information from our systems in accordance with our data retention policies and procedures.
California Consumer Privacy Act
Requests to Know, Correct, or Delete
Please see the section above “Integrity and Personal Information Rights” for where to submit requests.
Direct Creditor Requests
If you are a consumer in collection, information concerning how you can exercise your rights directly with the creditor or current creditor of your account can be found here.
Email: firstname.lastname@example.org if you are a consumer whom we are collecting from, or email@example.com for all other consumers (e.g., if you are an applicant, employee, former employee, business contact, etc.)