Privacy Policy and State and Local Disclosures

CALIFORNIA CONSUMER PRIVACY ACT NOTICE FOR CALIFORNIA RESIDENTS

Last Updated 5/29/2024

This Notice applies to individuals who reside in the State of California and to the extent that we have collected information subject to the California Consumer Privacy Act of 2018 (“CCPA”). It is a supplement to, but does not replace, Unifund’s general Privacy Policy. Terms used in this Notice that are defined in the CCPA have the same meaning as they do in the CCPA.

The CCPA defines “personal information” as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

The term “personal information” does not include publicly available information or lawfully obtained, truthful information that is a matter of public concern or consumer information that is deidentified or aggregate consumer information. In addition, the CCPA does not apply to certain activities and/or types of information, like:

(1) personal information collected, processed, sold, or disclosed subject to the federal Gramm-Leach-Bliley Act (Public Law 106-102), and implementing regulations, or the California Financial Information Privacy Act (Division 1.4 (commencing with Section 4050) of the Financial Code), or the federal Farm Credit Act of 1971 (as amended in 12 U.S.C. 2001-2279cc and implementing regulations, 12 C.F.R. 600, et seq.);

(2) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”); and

(3) an activity involving the collection, maintenance, disclosure, sale, communication, or use of any personal information bearing on a consumer’s creditworthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living by a furnisher of information, as set forth in Section 1681s-2 of Fair Credit Reporting Act.

This Notice does not apply to the activities and categories described in the preceding paragraph and list.

What information do we collect and for what purpose?

We may collect and may have collected the following categories of personal information from consumers within the last 12 months. Inclusion of a category indicates that we may collect some information in that category. It does not mean that we collect all information listed in that category in all situations.

Sources of Personal Information We Collect

We collect personal information directly from the clients to whom we provide services, from consumers and their agents, and from third-parties that assist us with respect to the services we perform for our clients. We also collect information from the following categories of sources:

• From publicly accessible sources (e.g., property records or court records);

• From your transactions with us;

• Government entities;

• From our service providers (e.g., correspondence vendors, location vendors, payment processing vendors, and electronic signature service providers);

• Directly from a third party (e.g., third parties contacted during location activities pursuant to 15 U.S.C. §1692b, such as your friends, neighbors, relatives, and/or employer);

• Consumer reporting agencies (CRAs);

• From a third party with your consent (e.g., your authorized representative and/or attorney); and

• From activity on our website.

How We Use Your Information

Personal information is collected for the purpose of debt recovery in a lawful manner and remains part of our records until we determine the information is no longer needed or we are required by law to delete such information. We may also use personal information that you provide to us to fulfill or meet the reason you provided such information. Your personal information will also be used to perform services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, verifying customer information, processing payments, providing analytic services, or providing similar services (“Services”). We may also use your information to respond to law enforcement requests and as otherwise permitted by applicable law, court order, or governmental regulations, to ensure security and integrity of the personal information, and to prevent fraud.

Sensitive personal information is collected only as necessary to perform our Services, process payments, maintain or service your account, to ensure security and integrity regarding the use of such personal information, and to verify or maintain the safety and quality of the Services. Sensitive personal information is not collected with the purpose of inferring characteristics about you.

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

We do not sell and will not sell your personal information.

How We Share Your Information

Unifund may share personally identifiable information it collects with its employees who need to know that information to provide collection services with respect to your account. Except as provided below, Unifund will not share or disclose any personally identifiable information with any nonaffiliated third-party company or marketing group without your express permission. Unifund may share your personal information with nonaffiliated third parties to the extent it is reasonably necessary to manage or service your account, process payment, fulfill a transaction, respond to court orders and legal investigations, report to credit bureaus; , or as otherwise authorized by law. Further, Unifund may disclose personally identifiable information to a nonaffiliated third party (i) with which Unifund enters or reasonably may enter into a corporate transaction, such as, for example, a merger, consolidation, acquisition, or asset purchase, (ii) 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 in connection with litigation brought against, or on behalf of, Unifund, where appropriate, (iii) if determined by Unifund in its sole judgment that such disclosure is appropriate to protect the life, health, or property of Unifund or any other person or entity, all in compliance with applicable law, (iv) as authorized or designated by you, or (v) to conduct any other legitimate business activity not otherwise prohibited by law. The foregoing is not intended to obviate or displace any legal obligations or duties applicable to Unifund.

We will not disclose personally identifiable information to affiliates or non-affiliated third parties except as set forth in this Policy.

Your Rights and How to Exercise Them

The CCPA provides California consumers with certain rights regarding their personal information, as described below.

The right to access personal information – You have the right to submit a verifiable request for access to your personal information that we collected about you, subject to certain exceptions. This may include the categories and specific pieces of information collected, the sources of that information and the business or commercial purpose for the collection or disclosure of that information.

The right to request correction of personal data we hold about you – You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate or incomplete, subject to certain exceptions.

The right to request deletion of personal information – You have the right to request that we delete your personal information, subject to certain exceptions. For instance, state and federal law may prohibit us from deleting personal information, which Unifund will disclose to you.

The right to non-discrimination –You have the right to be free from discrimination for exercising your rights under the CCPA.

Who can submit a request – A Verifiable consumer request may be submitted by a consumer, by a consumer on behalf of the consumer’s minor child, or by a natural person or a person registered with the California Secretary of State, authorized by the consumer to act on the consumer’s behalf, and that Unifund can reasonably verify, pursuant to regulations adopted by the Attorney General pursuant to paragraph (7) of subdivision (a) of Section 1798.185 to be the consumer about whom the business has collected personal information. A request must provide information sufficient for us to verify that the requester is the person about whom we collected personal information or an authorized representative.

You can designate an authorized agent to make any of these requests by providing your express written authorization. We must be able to verify your identity and the authorization must include the authorized agent’s name, address, telephone number, and email address (for providing the personal information collected or to respond to a request for deletion).

We must be able to verify your identity and the authorization must include the authorized agent’s name, address, telephone number, and email address (for providing the personal information collected or to respond to a request for deletion). To prevent anyone other than you, or your authorized agent, from exercising the right to know or the right to delete with respect to your personal information, we follow procedures to verify your, or your agent’s, identity. These procedures seek to confirm that the person making a request is the person about whom we have collected personal information or that person’s authorized agent. The verification procedures involve matching data points that you provide with your request against information about you we already have in our records and that we have determined to be reliable for purposes of verifying your identity. We will use information you provide in your completed request form to verify your identity, and we may request additional information if necessary to complete the verification process.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we are permitted to charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. If we refuse to comply with your request, we will notify you of the reason for refusing the request.

If you wish to exercise any of these rights, please contact Unifund by doing one of the following:

1. By mailing a request to:

Unifund CCR Partners,

PO Box 42121,

Cincinnati, OH 45242-0121

2. Contacting us toll free at (888) 384-8134

3. Interactive Webform

The State Rosenthal Fair Debt Collection Practices Act and the federal Fair Debt Collection Practices Act require that, except under unusual circumstances, collectors may not contact you before 8 a.m. or after 9 p.m. They may not harass you by using threats of violence or arrest or by using obscene language. Collectors may not use false or misleading statements or call you at work if they know or have reason to know that you may not receive personal calls at work. For the most part, collectors may not tell another person, other than your attorney or spouse, about your debt. Collectors may contact another person to confirm your location or enforce a judgment. For more information about debt collection activities, you may contact the Federal Trade Commission at 1-877-FTC-HELP or www.ftc.gov.

California License Information: