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Asset Recovery Solutions, LLC
Privacy Policy
Last Updated: December 5, 2023
I. Who Are We?
Asset Recovery Solutions, LLC, located in Des Plaines, Illinois, U.S.A., is a full-service asset recovery management company that works with credit issuers and accounts receivable portfolio owners to provide customized solutions across a vast array of asset categories.
If you have any questions or comments about this Privacy Policy or our practices, or wish to make a request regarding your Personal Information, please contact us as follows:
Asset Recovery Solutions, LLC
2200 E. Devon Avenue
Des Plaines, IL 60018
Toll-Free: 877-739-4168
II. Who and What is Covered By This Privacy Policy?
This Privacy Policy describes Asset Recovery Solutions, LLC’s policies and practices regarding its collection and use of your personal data, and sets forth your privacy rights. This Privacy Policy applies both to Asset Recovery Solutions, LLC’s online information gathering and dissemination practices in connection with this website (the “Site”), and personal information collected or received offline from you or other sources.
If you have arrived at this Privacy Policy by “clicking” on a link directing you to a Site operated by Asset Recovery Solutions, LLC, then this Privacy Policy applies to you and such Site.
This Privacy Policy does not apply to any website owned and/or operated by or on behalf of any third party, even if our Site posts a link to those third party websites and you click through from our Site. Third party websites have different and separate privacy policies. We have no control over the content of those linked sites, and no liability for their content, business practices, or treatment of your information. To the extent that you disclose information to other sites, you are subject to the privacy policies and practices of those sites. This Privacy Policy only addresses our use and disclosure of information that we collect.
Use of our Site is strictly limited to persons who are of legal age in the jurisdictions in which they reside. You must be at least eighteen (18) years of age to use our Site. If you are not at least 18 years of age, please do not use or provide any information through this Site.
When you use the Site, you consent to the use of your information in the manner specified in this Privacy Policy. This policy may change periodically, as we undertake new personal data practices or adopt new privacy policies, so please check back from time to time. By your continued use of the Site, you consent to the terms of the revised policy.
III. What Personal Information Do We Collect, From Where, And Why?
The following is a description of: (i) the categories of Personal Information we may have collected in the preceding 12 months; (ii) the sources from which we may have collected it; and (iii) the business purposes for which we may have collected it.
A. Information we do NOT knowingly collect.
We do not knowingly solicit or receive information from or about minors (under the age of sixteen) or persons residing outside the U.S.A.
B. Information that You provide to us directly.
We do not collect information from you when you use this Site, unless you voluntarily provide it to us.
Should you submit or otherwise disclose Personal Information to us (e.g., name, address, telephone number, email address, date of birth, social security number, account numbers, financial information, credit card or banking information, etc.), whether submitted or disclosed by mail, e-mail, telephone, fax or electronically, it is governed by this Privacy Policy.
If you initiate contact or correspond with us, we may keep a record of your contact information and correspondence, whether oral or written, and we reserve the right to use your contact information, and any other information that you provide to us in your message, to respond thereto, optimize customer service, or attempt to resolve your request or inquiry. Thus, we may use this Personal Information to further correspond with you or to accept payment on or otherwise manage your account.
If you wish to change or correct any information voluntarily submitted to us, please do so by contacting us in the manner described below.
Please note that all of your communications with us are with a debt collector, in an attempt to collect a debt. Any information obtained will be used for that purpose.
C. Information from Third Parties acting on your behalf.
We may receive and maintain Personal Information (e.g., name, address, telephone number, email address, date of birth, social security number, account numbers, financial information, etc.) contained in communications with someone other than you, such as your spouse, power of attorney, authorized representative, or your attorney, in connection with the collection of any debt.
D. Information we receive from Clients.
We receive and maintain Personal Information contained in the accounts receivable within the portfolios that we service for our clients, including credit issuers and accounts receivable portfolio owners. This information may include a name, date of birth, consumer’s social security number, information contained on credit applications, the original creditor’s account number, employment information, court records, the balance of the account at the time of sale, and the last date a payment was received on the account. We use this information to seek the collection and recovery of those accounts receivable and to fulfill our responsibilities to our clients in our role as a service provider.
E. Information we receive from our Service Providers.
We may receive and maintain Personal Information from our Service Providers. Service Providers are persons or entities that we contract with to provide a material service in connection with the recovery of accounts. This includes, for example, location service providers, attorneys, collections agencies, letter vendors, and data service providers that scrub information. Information that we typically may receive includes residential address, phone numbers, bankruptcy activity, active military status, death or probate status, court records, payment records, and correspondence or call recordings with consumers.
F. Information we receive from Credit Reporting Bureaus.
We receive and maintain Personal Information provided by one or more of the major Credit Reporting Bureaus. We use this information to seek the collection and recovery of those accounts receivable and fulfill our business responsibilities to our clients. This information and the consumer reporting agencies are covered by the federal Fair Credit Reporting Act .
G. Information collected by Use of this Site
We do not use cookies or collect information about you (e.g., name, address, geolocation, IP address, Site usage, etc.) when you simply visit or use this Site.
IV. What Personal Information Do We Share With Others?
A. We Do Not Sell Personal Information to Third Parties for their Own Use.
Asset Recovery Solutions, LLC does not sell to third-parties for their own use any of your Personal Information. Except as described in this Privacy Policy, we also do not disclose to third-parties information about your visits to our Site. Accordingly, there have been no sales of non-public Personal Information to Third-Parties for their own use or further disclosure in the past twelve (12) months.
Asset Recovery Solutions, LLC does not knowingly collect and does not, and will not, sell non-public Personal Information of minors under 16 years of age without first obtaining affirmative authorization.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties
B. Reporting to Consumer Credit Agencies.
Asset Recovery Solutions, LLC may provide monthly reports to the three major Consumer Credit Agencies containing Personal Information about the status and current balance of active consumer debt accounts that it is servicing for clients. This information and the consumer reporting agencies are covered by the federal Fair Credit Reporting Act.
C. Sharing Personal Information with Clients Pursuant to a Written Contract Through Which We Act as a Service Provider.
We may provide your Personal Information to our clients, typically credit issuers or accounts receivable portfolio owners, that engage us as a Service Provider, through a written contract, for the purpose of attempting to recover on accounts and fulfilling our contractual responsibilities. The types of Personal Information we may share with our clients include updated contact information and payments on our account.
D. Sharing Information with Service Providers That Help Us Perform Our Business Activities.
We may share your Personal Information to other persons or entities that we contract with, referred to as Service Providers, to provide a material service in connection with our attempt to perform our contractual obligations to our clients. Our Service Providers include location service providers, data service or security providers, and technological support companies.
In connection with providing these business services to Asset Recovery Solutions, LLC, one or more of our Service Providers may have access to identifying Information, such as your name, address, or social security number. We restrict our Service Providers from accessing or using your Personal Information for any purpose other than as reasonably necessary to perform a business purpose that we authorize in the contract, and your Personal Information will not be further used by our Service Providers or disclosed to any Third Party.
E. Sharing Personal Information at Your Direction.
We may share your Personal Information with Third Parties to whom you or your agents authorize us in advance to intentionally disclose to or allow to use your Personal Information in connection with the services that we provide.
F. Sale of our Company or Company Assets.
In the event of a sale, assignment, liquidation, or transfer of our assets or of any portion of our business, we reserve the right to transfer any and all information that we collect from individuals, or that we otherwise collect in connection with the Site, to unaffiliated third-party purchasers.
G. Monitoring, Law Enforcement and Legal Requests.
Asset Recovery Solutions, LLC reserves the right, at all times, to monitor, review, retain and/or disclose any information, to the extent possible, including non-public Personal Information, as may be necessary to satisfy any applicable law, regulation, legal process or governmental request or to cooperate with or comply with requests from law enforcement and other authorities.
H. Our Internal Use and Research
Asset Recovery Solutions, LLC reserves the full and unrestricted right to use and disclose de-identified information; anonymized information; aggregated information or publicly available information that has not been combined with nonpublic Personal Information for purposes including, but not limited to, our own internal use, data mining, and research.
V. How Do We Protect Your Personal Information?
Asset Recovery Solutions, LLC takes reasonable security procedures and practices appropriate to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration and destruction. We maintain physical, electronic and procedural safeguards designed to protect against the unauthorized disclosure of Personal Information, and Personal Information is disposed of properly and securely utilizing industry standards. Our data security policies and practices are periodically reviewed and modified as necessary, and subject to third party assessments annually.
** THE INFORMATION BELOW APPLIES TO CALIFORNIA RESIDENTS **
VI. Your Rights Under The California Consumer Privacy Act.
A. The CCPA and Personal Information.
The California Consumer Privacy Act (“CCPA”), effective as of January 1, 2020, grants privacy rights to California consumers in connection with their Personal Information.
Personal Information or “PI” is “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”
A consumer has rights regarding his/her PI, including:
• A right to know what PI is collected, used, shared or sold by the business;
• A right to access PI collected and retained by the business;
• A right to require businesses and, by extension, their service providers, to delete PI, subject to certain exceptions;
• A right to opt-out of the business’ sale of PI; and
• A right to non-discrimination in terms of pricing or service for choosing to exercise a privacy right under the CCPA.
B. Consumer Right to a Notice of Collection.
A business subject to the CCPA must, at or before the point of collection of PI, inform a consumer as to the categories to be collected and the purposes for which it shall be used. A service provider that receives or collects PI on behalf of, or at the direction of, a covered business may not be required to provide a notice of collection to the consumer.
C. Consumer Right to Know.
A covered business must disclose in its privacy policy the PI it has collected, sold, or disclosed for a business purpose in the past 12 months.
Collection: A business must disclose the following in response to a verifiable request:
• The categories of PI the business has collected about the consumer;
• The categories of sources from which that PI was collected;
• The business or commercial purpose for collecting or selling PI;
• The categories of third parties with which the business shares PI; and
• The specific pieces of PI the business has collected about the consumer making the request;
Sale: A business that sells PI or discloses it for a business purpose must disclose, in response to a verifiable request, the following:
• The categories of PI collected about the individual consumer
• The categories of PI the business sold about the individual consumer, and the categories of third parties to which it was sold. Or, if the business has not sold any of the consumer’s PI, it must state that fact.
• The categories of PI the business has disclosed about the individual consumer for a business purpose. Or, if the business has not disclosed the consumer’s PI for a business purpose, it must state that fact.
D. Consumer Right to Delete.
A California consumer has the right to request that a covered business delete his/her PI, subject to certain exceptions. Once a request is reasonably verified by the covered business, the PI requested to be deleted must be removed from the records held by that business. The business must also direct its Service Providers with whom the information was shared to also delete the information, unless it is subject to an exception.
A request to delete may be denied if retaining the information is necessary to:
1. Complete the transaction for which it collected the PI, provide a good or service requested by the consumer, take action reasonably anticipated within the context of the ongoing business relationship with the consumer, or otherwise perform a contract with the consumer.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. 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 the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on the consumer’s relationship with the business.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of the information that are compatible with the context in which the consumer provided it.
E. Consumer Right to Non-Discrimination.
A business must not discriminate against a consumer who exercises CCPA rights. A business may charge different prices or provide a different quality of goods or services, but only if the difference is reasonably related to the value provided to the consumer by the consumer's data. A business may offer financial incentives to a consumer for the collection, sale, or deletion of personal information on a prior, opt-in consent basis.
F. Consumer Right to Opt-Out.
A business that sells PI to third parties must provide notice to consumers, clearly inform them of the right to opt out of the sale, and provide a "Do Not Sell My Personal Information" link on its website that enables the consumer to opt out of future sales.
A business is prohibited from selling the PI of a consumer the business knows is less than 16 years of age, unless (for a child between 13 and 16 years of age) the child has affirmatively authorized the sale or (for a child less than 13 years of age) the child’s parent or guardian has affirmatively authorized the sale.
G. Privacy Policy Requirements.
A business must include the following in its privacy policy, to be updated every 12 months:
• A description of consumer CCPA rights, including the right to opt out of the sale of PI and a separate link to a "Do Not Sell My Personal Information" internet webpage if the business sells PI;
• The method(s) by which a CCPA request can be submitted; and
• A list of the categories of PI the business has collected, sold, or disclosed for a business purpose in the preceding 12 months.
VIII. How Do I Exercise My CCPA Rights?
A. Instructions For Submitting A CCPA Consumer Rights Request To Us
If you are a California resident and wish to exercise any of your CCPA rights, such as a Request to Know or a Request to Delete your Personal Information, you may submit your request to Asset Recovery Solutions, LLC using one of the following methods:
For CCPA Inquiries, Call us, Toll-Free, at: 877-739-4168
Please be advised that we are only required to respond to your request to know - for access or data portability – two times in any 12-month period.
We are required to keep records of your CCPA request for at least 24 months, including any assigned reference number, the request date and nature of the request, the manner in which the request was made, the date and nature of our response, and the basis for the denial of the request if the request is denied in whole or in part.
B. Verification Of The Person Making A Consumer Rights Request.
Asset Recovery Solutions, LLC needs to be reasonably sure that the person making the request about your PI is you, or a representative authorized to make a request on your behalf.
We cannot comply with your request if we cannot verify your identity or your authority to make a request for another person. Accordingly, we will ask for information, such as your full name, mailing address, or account number, that will allow us to attempt to verify your identity.
To the extent possible, we will not ask you for new information to verify your identity, but will instead ask for information that we can cross-check from existing records. If we are unable to verify your request without new information, we will delete that new information as soon as practical after processing your CCPA request, except as may be required to comply with the CCPA’s request record retention requirements.
We will never require you to create an account with us in order to verify your request. We will only use information you provide to us during the verification process to try to verify your identity or your authority to make the request for another person.
Please note that certain requests require different levels of verification, depending on the sensitivity of the information at issue. For example, if you request to know the specific pieces of information we hold, and not just the categories, we will also require you to submit a written declaration under penalty of perjury that you are the consumer whose PI is the subject of the request. In addition, certain pieces of information, such as a social security number, driver’s license number or other government-issued identification number or financial account numbers, will not be disclosed in response to a CCPA request.
If you wish to authorize someone else to act on your behalf in connection with your CCPA rights, we must receive proof that this person is authorized to do so. Proof can be provided by a consumer verifying his/her own identity directly with us and then providing written authority for a designated person to act on the consumer’s behalf, or through receipt of a power of attorney or proof that the person is registered with the California Secretary of State as your designated representative. You may also make a verifiable consumer request on behalf of your minor child.
C. How and When Will We Respond?
Within 10 days of receipt of your request, we will provide an initial confirmation with an assigned ticket number by email or U.S. Mail.
If you submit a Request to Delete, we will re-confirm your choice to delete the information after verifying your request.
Asset Recovery Solutions, LLC strives to provide a response to a verifiable consumer request within 45 days of receipt of the request, regardless of the time it takes to verify the request. If we need additional time, we will let you know.
We will send our response to your request by U.S. mail or email, at your option. Any information we provide will cover only the 12-month period preceding receipt of your request.
If we cannot respond to or comply with your Request to Know or Request to Delete, because, for example, we cannot verify your identity or because an exception applies, we will explain our reasoning and decision in our response.
For data 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.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded, and we have informed you in writing of the reasoning behind a charge and its estimated cost. We will provide a cost estimate before completing your request if we determine that a charge is warranted.
Asset Recovery Solutions, LLC
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