California Consumer Privacy Act

This section is intended for California residents pursuant to the California Consumer Privacy Act of 2018 (CCPA). Terms defined in the CCPA and applicable California Office of the Attorney General Regulations have the same meaning as used in this section.

What is the definition of “Personal Information” under the CCPA?

The CCPA defines “Personal Information” as 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.”

Williams & Fudge, Inc. does not sell any consumer Personal Information.

What Categories of Information Does Williams & Fudge, Inc. Collect?

Williams & Fudge, Inc. (“WFI”) may receive, collect and use Personal Information for purposes of collecting debts on behalf of its creditor clients.

WFI collects and has collected in the last twelve (12) months the following types of Personal Information offline and on WFI’s website regarding collection accounts placed with us:

WFI will not collect additional categories of Personal Information or use the Personal Information collected for materially different purposes than the collection of debts without providing you notice.

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”).

The Categories of Sources From Whom We Collected This Personal Information Are:

• Directly from you or your authorized representative(s);
• Service providers, business partners; and/or
• Websites, such as social networks.

WFI may also be considered a “Service Provider” to its creditor clients

The Categories of Third Parties to Whom We Disclosed Personal Information for Our Business Purposes (Debt Collection) Described in This Privacy Disclosure Are:

• Vendors and service providers who provide such services as payment processing, printing services, and communication services;
• Business partners who provide services such as legal expertise; and/or
• Government Agencies as required by laws and regulations.

How WFI Collects Your Personal Information

WFI collects most of this Personal Information from our creditor clients or directly from you or your authorized representative(s) via telephone, written communications, or your activity on WFI’s website. However, WFI may also collect information from publicly accessible sources and from our service providers.

Why Does WFI Collect This Personal Information?

WFI uses the Personal Information above strictly for the following purposes:

• Providing you with information and services;
• Verifying your identity;
• Performing collection services on behalf of our clients related to your account(s);
• Conducting data analysis;
• Improving customer service;
• Processing your payment(s) (although online payments are processed via a secure third party payment processor);
• Auditing related to consumer interactions;
• Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity and prosecuting those responsible for that activity;
• Ensuring compliance with all other applicable laws and regulations, including the FDCPA;
• Responding to civil, criminal, or regulatory requests;
• As appropriate to protect the rights, property, or safety of us, our creditor clients, or others; and/or
• As described to you when collecting your Personal Information or as otherwise described in the CCPA.

WFI regularly discloses and has disclosed in the last twelve (12) months the following types of Personal Information for one or more business purposes: Name, address, email address, Social Security number, date of birth, employment information, contact information, payment and financial information, age, marital status, sex, and veteran or military status, audio information, and information collected or shared pursuant to HIPAA, GLBA, FCRA, DPPA, and/or other applicable privacy laws.

Does WFI Sell Any Personal Information?

WFI does not sell any Personal Information and will not sell your Personal Information.

CCPA Consumer Rights

The CCPA provides California consumers with additional rights regarding their Personal Information.

Right to Request

Subject to the exceptions set forth in California Civil Code section 1798.145, you have the right to request that we disclose the categories of Personal Information WFI has collected, used, or disclosed about you in the preceding 12-month period. We must also provide you with a summary of the purposes for which the categories of Personal Information were collected. We must also provide you with the categories of sources from which the Personal Information was collected, the categories of third parties with whom we share Personal Information, if any, and the specific pieces of Personal Information we have collected about you.
WFI will disclose the applicable information specified above to you upon receipt of your verifiable consumer request (see “Submitting a Verifiable Consumer Request” section below).

Right to Deletion

You have the right to request that we delete any of your Personal Information subject to the various exceptions provided in the CCPA (see “Submitting a Verifiable Consumer Request” section below).

Please note: Deletion requests are subject to certain exceptions.

WFI may deny your deletion request if we are acting in the role of a service provider to another business regarding the applicable Personal Information. If we deny your request on that basis, we will generally refer you to the relevant business. In addition, we may deny your deletion request if retaining the information is necessary for WFI or our service providers to:

• • Complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and WFI;
  • 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 a right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • 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.

Submitting a Verifiable Consumer Request
In order to protect your information, we can only honor requests to know or deletion requests upon receipt of a verifiable consumer request. Your request must provide information that enables us to verify your identity in order for us to respond.

You agree to respond to any reasonable requests from us for additional information to enable us to verify your identity in connection with your access or deletion requests.

You may submit a verifiable consumer request by either of the following methods:

• Sending an email to ccpa@wfcorp.com
• Completing the CCPA request form here.

Upon receiving a request, we will attempt to verify your identity and will respond within no more than forty-five (45) days as required by the CCPA. If WFI reasonably needs additional time to comply, WFI will notify you of the need for additional time no more than forty-five (45) days after receipt of your verifiable consumer request.

Once you have submitted a valid request, you will be issued a reference number.

Please note that we are not required to:

• Provide the requested information disclosure if a CCPA or applicable exemption applies.
• Provide the requested information disclosure if we are unable to verify that the individual making the request is the individual about whom we collected information or is someone authorized to act on such individual’s behalf.
• Retain 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 sold or retained.
• Provide the requested information disclosure more than twice in a 12-month period.
• Re-identify or otherwise link information that is not maintained in a manner that would be considered Personal Information.

Authorized Agent Designation
California residents have the right to designate an authorized person or corporate entity to exercise rights granted to them under the California Consumer Privacy Act (CCPA). To make this designation, California residents may complete and submit this form here.

Right To Nondiscrimination
WFI will not discriminate against you because you elect to exercise any of your rights under the CCPA including, but not limited to:

• Denying a good or service to you;
• Charging you different prices or rates for services, including through the use of discounts or benefits or imposing penalties on you;
• Providing a different level or quality of services to you; or
• Suggesting that you will receive a different price or rate for services or a different level or quality of services.

If you have questions or concerns about WFI’s privacy policies and/or practices, you may reach a representative at 800.849.9791.

Last Updated: 10/1/2020