Privacy Policy

DebtCommand.com
U.S. PRIVACY POLICY

DebtCommand.com.com and its subsidiaries and affiliates (referred to in this Privacy Policy as “DebtCommand.com,” “us,” “we,” and/or “our”) value you as a customer and take your personal privacy seriously. In the course of providing you with products and services, we may collect certain information from or about you. We are providing this Privacy Policy to explain our practices and policies for collecting, using and sharing information collected from or about you when you visit, access, or use, or provide information to us in connection with, one of the DebtCommand.com Properties, DebtCommand.com Websites or DebtCommand.com Mobile Apps, as each term is defined below in Section 1 (referred to together as the “DebtCommand.com Services”). By visiting, accessing, or using, or providing information to us in connection with, the DebtCommand.com Services, you expressly consent to our collection, storage, use and sharing of your information as described in this Privacy Policy. Please note that if you disagree with anything in this Privacy Policy, you should not visit, access, or use, or provide information to us in connection with, the DebtCommand.com Services.

This Privacy Policy does not create a contractual obligation between you and DebtCommand.com

1. DEFINED TERMS

As used in this Privacy Policy:

(a) “DebtCommand.com Websites” refers to websites owned or operated by DebtCommand.com that display this Privacy Policy, including, but not limited to, DebtCommand.com.com.

(b) “DebtCommand.com Mobile Apps” refers to mobile applications owned or operated by DebtCommand.com that display this Privacy Policy, including, but not limited to, the DebtCommand.com Rewards® mobile application.

(c) “Personal information” refers to any information by which you can be personally identified, such as your first name, last name, address, phone number, email address, credit card number, social security number, driver license number, passport number, geolocation information, date of birth, purchase information, biometric information and other similar information.

(e) “Non-personal information” refers to information by which you cannot be personally identified.

2. INFORMATION WE MAY COLLECT.

We collect and use information we believe is necessary to administer and promote our business and provide you with the products and services you request. We may collect and maintain both personal information and non-personal information needed for these purposes. Your personal information and/or non-personal information will be referred as your “information” in this Privacy Policy.

3. HOW WE COLLECT YOUR INFORMATION.

(a) Information You Directly Provide to Us. You may provide information directly to us under a wide range of circumstances, such as when you submit information to us through the DebtCommand.com Websites or DebtCommand.com Mobile Apps, use any Debt Relief or non-Debt Relief services at a DebtCommand.com Property sign up to receive email or text messages from us, sign up to access Wi-Fi at a DebtCommand.com Property, install or use one of the DebtCommand.com Mobile Apps, sign up for DebtCommand.com Rewards, log in as a DebtCommand.com Rewards member.

(b) Information Automatically Collected Through the DebtCommand.com Websites.

(i) Traffic Data. We automatically track and collect general log information when you visit the DebtCommand.com Websites, including your: (A) Internet Protocol (IP) address, (B) domain server, (C) operating system, and (D) type of Web browser as well as the pages you visit on the DebtCommand.com Websites (collectively “Traffic Data“). Traffic Data does not personally identify you, however, if you choose to provide us with personal information, we may store some items of your personal information and use it with the Traffic Data to better personalize your experience on the DebtCommand.com Websites. We use the Traffic Data to report aggregated website activity and to better understand the needs of our users so we can make informed decisions regarding the content and design of the DebtCommand.com Websites. It enables us:

• to estimate our audience size and usage pattern;
• to learn what information is of most and least interest;
• to speed up your searches; and
• to learn of any possible DebtCommand.com Website performance problems.

We, or our service providers, may also use Traffic Data to identify your physical location to confirm that you are in a jurisdiction where you can use our online Debt Relief services. We may collect Traffic Data through various technologies including, but not limited to, cookies, IP addresses, and transparent GIFs (Graphics Interchange Format, a software technology also known as a pixel tag).

(ii) Data Collected Using Cookies and Other Technologies. We also automatically collect information from you using cookies and other technologies on the DebtCommand.com Websites. Cookies are small text files offered to your computer by servers in order to keep track of your browser as you navigate the DebtCommand.com Websites. Cookies may be stored on your hard drive in which case they remain on your hard drive until deleted, or in temporary memory in which case they are deleted when you shut down your browser or turn off your computer. We may use cookies and similar technologies to identify who you are and may use them when you visit the DebtCommand.com Websites, click on our ads, or open our emails. Cookies also enable us to remember your user preferences for the DebtCommand.com Websites. Cookies and other technologies may also be used for site maintenance and analysis, performing network communications, authenticating users, serving contextual advertisements, and protecting against fraud and theft. You can block or remove cookies using your Internet browser’s settings. If you block or remove cookies, your ability to perform certain transactions, use certain functionality, and access certain content on the DebtCommand.com Websites may be affected. To find out more about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit http://www.allaboutcookies.org.

(iii) Information Collected by Third Parties through Third Party Links and Content. The DebtCommand.com Websites and DebtCommand.com Mobile Apps may include links to other websites and other content from third party businesses. These third party businesses may use cookies, web beacons or other similar technology to collect information about you. DebtCommand.com does not have access to or control over these third parties or the cookies, web beacons or other technology that these third parties may use. We are not responsible for the privacy practices of these third parties or the content on any third party website. You are encouraged to review the privacy policies of the different websites you visit and of the advertisers whose ads you may choose to click while on the DebtCommand.com Websites (see Section 7 below for additional information about Online Advertising).

(iv) Information Collected by Third Party Analytics Services. We may work with third party analytics services to help us understand how the DebtCommand.com Properties, DebtCommand.com Websites or DebtCommand.com Mobile Apps are being used, such as tracking the frequency and duration of use of the DebtCommand.com Websites or DebtCommand.com Mobile Apps. These analytics services may use cookies and other technologies to collect information about the content you view, what websites you visit immediately prior to and after visiting the DebtCommand.com Websites, and your system information and geographic information. The information generated by these technologies about your use of the DebtCommand.com Websites or DebtCommand.com Mobile Applications will be transmitted to and stored by the applicable analytics services. The information collected by these analytics services allows us to analyze your use of the DebtCommand.com Websites or DebtCommand.com Mobile Apps.

(v) Information You Share on Third Party Websites or through Social Media Services. The DebtCommand.com Websites may include links to third party websites and social media services where you will be able to post comments, stories, reviews or other information. Your use of these third party websites and social media services may result in the collection or sharing of information about you by these third party websites and social media services. We encourage you to review the privacy policies and settings on the third party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third party websites and social media services. We may also monitor sentiments regarding DebtCommand.com that you publicly post on social media services or customer review sites. We may reach out to you regarding these postings to address customer service issues and to otherwise help ensure that you have a positive customer experience.

(vi) Information You Post on the DebtCommand.com Websites. If you post information on any public areas of the DebtCommand.com Websites, that information may be collected and used by DebtCommand.com, other users of the DebtCommand.com Websites, and the public generally. We strongly recommend that you do not post any information through the DebtCommand.com Websites that allows strangers to identify or locate you or that you otherwise do not want to share with the public.

(c) Information Obtained from Other Sources, including from Service Providers, Third Party Services and Joint Marketing Partners. We may obtain information about you from other sources, including service providers, third party services (such as data brokers or analytics firms), publicly available sources, government agencies or Joint Marketing Partners (defined below), and we may combine such information with information we have collected about you as described in this Privacy Policy. To the extent we combine such third party information with other personal information we have collected, we will treat the combined information as personal information under this Privacy Policy. We are not responsible for the accuracy of any information provided by third parties or third party policies or practices.

(d) Information We Automatically Collect Through the DebtCommand.com Mobile Apps, including Location Information. If you install or use one of the DebtCommand.com Mobile Apps, we may collect and use information regarding your mobile device, including but not limited to technical information about your mobile device, system and application software, and peripherals, that is gathered periodically to facilitate any upgrades, product support and other services to you (if any) related to the DebtCommand.com Mobile Apps, and to provide services or technologies to you. In addition, if you install one of the DebtCommand.com Mobile Apps and allow your device to share location information with our Mobile App, we may be able to automatically identify and collect the location of your mobile device, including GPS location, which is the real-time geographic location of your mobile device. We may use your location information for any of the reasons disclosed in this Privacy Policy, including, for example, to provide you with more relevant content and useful app features, such as wayfinding services at DebtCommand.com Properties, or to confirm that you are located in a jurisdiction where you can use our mobile Debt Relief services. We may also use this data for statistical or business-related purposes to improve our products, services and properties. If you allow a DebtCommand.com Mobile App to send you push notifications, your location information may be used to send real-time offers for goods and services at DebtCommand.com Properties that are close to your location. You may adjust your device settings to turn off push notifications at any time. Location information may also be collected and used to tailor your marketing offers to your specific interests. You may choose not to share your location details with us by adjusting or turning off your mobile device’s location services settings; however, by doing so, you may not be able to use certain features provided through the DebtCommand.com Mobile App. Please note that even if you adjust the settings in your mobile device to turn off location sharing (via GPS data), we may be able to collect information about the location of your mobile device if you are located on one of the DebtCommand.com Properties through your Wi-Fi, Bluetooth, and other device settings. See subsection (f) below for more information.

(e) Other Information We Collect Related to Your Debt Relief and Purchase History with Us. When you use any of our Debt Relief services or make a purchase at any of the DebtCommand.com Properties, we may collect transactional information about these activities and store it with your customer account. We may use this information to determine your DebtCommand.com Rewards tier level (if you are a DebtCommand.com Rewards member) and to make predictions about your preferences, and interests, future spending and Debt Relief activity.  

4. HOW WE MAY USE YOUR INFORMATION.

We will use the information you provide to us for the specific purposes for which you provided the information, as stated at the time of collection, and as otherwise described in the Privacy Policy or permitted by law. The following are some other ways in which we may use your information to administer or promote our business and provide you with the products and services you request or may be of interest to you;
• to operate our DebtCommand.com Rewards Program;
• to improve the products and services we provide you and develop new products and services;
• to improve the DebtCommand.com Properties, DebtCommand.com Websites and DebtCommand.com Mobile Apps;
• to track your use of the DebtCommand.com Properties, DebtCommand.com Websites and DebtCommand.com Mobile Apps for our internal market research and analytics;
• to create a more accurate and complete customer profile for you to better understand and predict the products and services you want to use;
• to notify you about promotions and special offers regarding products and services provided by us or our affiliates or other associated third parties, including our Joint Marketing Partners (defined below);
• to ask for your participation in our internal market research;
• to generate aggregate statistical studies about our customers;
• to contact you in response to your inquiries, comments and suggestions;
• to provide a secure and safe environment for our guests or employees;
• to protect and defend our rights or property or enforce our agreements with you;
• to perform background checks for any reason (to the extent permitted by applicable laws), which includes but is not limited to any investigation into your identity, any credit checks or any inquiries into your personal history
• to cash your checks, extend you credit, process credit card, ACH and/or other financial transactions;
• to contact you otherwise when necessary; and
• otherwise with your consent or as permitted or required by law.

5. HOW WE SHARE YOUR INFORMATION WITH OUR AFFILIATES.

For business purposes, we may share certain information we receive from you, and about your transactions with us, with our affiliates, including our owned, operated, and managed online and web-based businesses, and other corporate entities or affiliates. Doing so allows us to provide the products and services you have requested and quickly respond to applications for credit or other financial services. We may also disclose your personal information to all DebtCommand.com Properties and other affiliates.

6. HOW WE SHARE YOUR INFORMATION WITH NON-AFFILIATED THIRD PARTIES. 

 As permitted by law, we may share the information we collect from and about you with non-affiliated third parties as follows:

(a) Third Party Service Providers. Your information may be shared with or collected by third party service providers who provide us with services, including but not limited to data hosting or processing, credit card processing, credit or background checks, or processing and fulfilling reservations or purchases. We require these providers to exercise reasonable care to protect your personal information and restrict the use of your personal information to the purposes for which it was provided to them.

(b) Third Party Joint Marketing Partners. We may share certain information about you with other companies with whom we have joint marketing or similar agreements, or other businesses with whom we have a contractual relationship (“Joint Marketing Partners”), who may contact you with marketing and promotional offers. These businesses generally include financial services companies, such as banks, insurance companies, debt relief programs, and other service providers, such as airlines, hotels and car rental agencies, and retailers, but may include others. If you would like us to stop providing your information to these Joint Marketing Partners, you may opt-out of personal information sharing by following the instructions in Section 11 below.

(c) Business Transfers; Bankruptcy. In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets (for example, a sale of one of the DebtCommand.com Properties to a third party), we may transfer or allow third parties to use information owned or controlled by us. We reserve the right, in connection with these types of transactions, to transfer or assign your information and other information we have collected from our customers to third parties or to authorize third parties to use any such information retained by us. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Privacy Policy. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.

(d) Response to Subpoenas or Court Orders or to Protect Rights and to Comply with Our Policies. To the extent permitted by law, we will disclose your information to government authorities or third parties: (i) if required to do so by law, or in response to a subpoena or court order, search warrant or other valid legal process, (ii) to comply with legal, regulatory or administrative requirements of any governmental authorities, including but not limited to Debt Relief regulators, (iii) in connection with any legal action, claim or dispute, including but not limited to the collection of debts, (iv) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large, or (v) we believe that you have abused a DebtCommand.com Website or DebtCommand.com Mobile Application by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.

(e) Aggregate Information. We may share your information with affiliated or non-affiliated third parties on an anonymous, aggregate basis. While this information will not identify you personally, in some instances these third parties may be able to combine this aggregate information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally.

7. ONLINE ADVERTISING; TRACKING.

(a) Online Advertising. DebtCommand.com and third parties may use the information collected through the DebtCommand.com Websites using cookies, web beacons, and other similar technologies to help manage online advertising programs. This information may enable advertising services to track the actions of users online over time and across different web sites or platforms to measure statistics relating to marketing efforts, and to deliver electronic advertisements that may be more relevant to individual consumers and that will improve the consumer experience. For information about how tracking works for online advertising purposes, and what happens when you elect a do-not-track option, visit http://www.aboutads.info/choices. For more information about the Network Advertising Initiative opt-out process, you may visit the Network Advertising Initiative website, available at: http://www.networkadvertising.org/managing/opt_out.asp.

(b) Do Not Track. Your browser may allow you to adjust your browser settings so that “do not track” requests are sent to the websites that you visit. However, at the present time we do not disable tracking technology that may be active on the DebtCommand.com Websites in response to any “do not track” requests that we receive from your browser.

8. YOUR CALIFORNIA PRIVACY RIGHTS. (a) Shine the Light. As provided under California Civil Code Section 1798.83, also known as the “Shine the Light” law, we provide our customers with the ability to “opt out” of having their personal information shared with independent affiliates and non-affiliated third parties for their direct marketing purposes. You may opt-out of having your personal information shared with these affiliated and non-affiliated third parties for their direct marketing purposes by following the opt-out instructions in Section 11 below.

(b) California Consumer Privacy Act. This section only applies to customers who are residents of California under the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws (together “California Laws”).

1. Information we collect.

2. California Residents’ Rights. Under California Laws, California residents can exercise three privacy rights (Access; Deletion; and “Do Not Sell My Personal Information”), which are described in more detail in Sections 9, 10 and 11 below (collectively, “Rights”). These Rights are not absolute and are subject to certain exceptions. For instance, we cannot disclose or permit access to specific pieces of personal information if the disclosure or access would present a certain level of risk to the security of the personal information, your account with us or the security of the business’s systems of networks.

Please note that California residents have a right not to be discriminated against for the exercise of their Rights.

Verification and Record-keeping. If you are a California resident, we will process your request to exercise your Rights in accordance with California Laws. When a request is made, we may first take steps to verify your identity to protect your privacy and security by asking you to provide information that matches information in our customer records. We may also require a declaration, signed under penalty of perjury, that you are the person whose personal information is the subject of the request. Further, if you designate an authorized agent to make a request on your behalf, you will have to submit information confirming such designation. A record concerning the requests may be maintained pursuant to our legal obligations. Further, we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive or manifestly unfounded.

9. ACCESS REQUESTS.

California consumers have the right to request that we disclose to them, for the 12-month period preceding the date of the request, (i) the categories of personal information we have collected about them, (ii) the categories of sources from which personal information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared personal information, and (v) the specific pieces of personal information we hold about an individual. Please note that we are only required to fulfill Access requests from a consumer twice per every 12-month period.

California residents can make a Access request, subject to the exceptions in the CCPA, by clicking here and filling out their information and emailing their request.

10. DELETION REQUESTS.

California consumers have the right to have their personal information deleted, subject to certain exceptions (for example, to comply with legal obligations, complete transactions or for our certain internal uses). In the course of fulfilling a valid deletion request, we will also endeavor to direct our service providers to delete your personal information from their records.


California residents can make a personal information deletion request, subject to the exceptions in the CCPA, by clicking here and filling out their information and emailing their request.

If you are a DebtCommand.com Rewards member, but not a California resident, and you make a “Deletion Request” by following the instructions above, we will deactivate your account and adjust account settings so that your data will not be shared with our marketing partners, and you will no longer receive any marketing communications from us.

10. “DO NOT SELL MY PERSONAL INFORMATION” REQUESTS.

California and Nevada consumers have the right to opt-out of having their personal information sold. Under the CCPA, the definition of “sale” includes a typical sale (i.e., a transfer of data from a seller to a buyer in exchange for money), but it also includes sharing of personal information with a third party in exchange for anything of value (money or otherwise). We may share personal information of DebtCommand.com Rewards members with our Joint Marketing Partners (defined in Section 6(b) above), including the issuer of the DebtCommand.com Rewards Visa card.


California residents, Nevada residents and all DebtCommand.com Rewards members can opt out from having personal information “sold” to third parties, subject to the limitations of California Laws and Nevada law, by clicking here and filling out their information and emailing their request.


Subject to applicable law, opting out through this mechanism will not prevent your personal information from being shared with third parties for non-marketing purposes (for example, to process one of your transactions). Further, this opt out mechanism will not prevent the transfer of personal information in connection with a merger, acquisition, bankruptcy or other sale of all or a portion of our assets as described in Section 6(c) above.

11. CHANGES TO OUR PRIVACY POLICY.

Over time, it may be necessary to modify or supplement our Privacy Policy. When we make changes, we will post the changes to the DebtCommand.com Websites and change the effective date at the top of the Privacy Policy. We encourage you to visit the DebtCommand.com Websites from time to time to review our Privacy Policy in the event it has changed. Your continued provision of information to us or use of the DebtCommand.com Services following the posting of changes to the Privacy Policy means that you accept the changes and our use of your personal information in accordance with the revised Privacy Policy. If we make any material changes to the Privacy Policy, we will notify you of changes at least thirty (30) days before the effective date of the changes. If you have provided us with your email address, we will also notify you of material changes to this Privacy Policy by sending an email at least thirty (30) days before the effective date of the changes to the email address you most recently provided to us. We encourage you to keep the email address you provide to us current, and to promptly notify us of any changes to your email address, so that you may receive any notices we send to you regarding material changes to this Privacy Policy. If you do not agree to the changes, you should discontinue your use of the DebtCommand.com Services prior to the time the modified Privacy Policy takes effect.

12. NON-U.S. RESIDENTS.

Unless otherwise specified, the DebtCommand.com Websites and DebtCommand.com Mobile Apps and material provided on or through the DebtCommand.com Websites and DebtCommand.com Mobile Apps are solely intended for users located in the United States and for promoting products, programs, and business operations within the United States. If you do not reside in the United States and you choose to access or use the DebtCommand.com Websites and/or DebtCommand.com Mobile Apps, or visit the DebtCommand.com Properties, and provide your personal information to us, it may be transferred to, processed and maintained on servers or databases located outside of the country or jurisdiction where you are located. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should not use the DebtCommand.com Websites and/or DebtCommand.com Mobile Apps or visit the DebtCommand.com Properties.

13. CONTACT INFORMATION.

Should you have additional questions, comments or concerns regarding this Privacy Policy or how we collect and use your information, you may click here to send an email or contact us by writing to:


        Connected Impression, LLC
        ATTN.: Loyalty Marketing
        533 Teak Dr
        Lake Park FL 33403

14. SPECIAL PROVISIONS FOR FINANCIAL SERVICES CUSTOMERS

If you are a customer who utilizes the credit, check cashing, front money, counter check account and/or cash advance services (“Financial Services”) at a DebtCommand.com Property in the United States, there are additional categories of information we may collect from or about you:

  • Information we receive on applications for credit or other financial services, such as your name, address, telephone number, Social Security number and other identifying information.
  • Information we receive about you from others, including credit bureaus, relating to your credit history and financial transactions with others.
  • Information about your transactions with us, including your payment history and/or Debt Relief activity with any DebtCommand.com Property.


As long as you are a current Financial Services customer, we will provide you with a copy of our current Financial Services privacy notice annually. If you no longer have a Financial Services customer relationship with us, we will continue to follow our Privacy Policy, but you will not receive annual notices from us in the future. Our current form of notice with additional information about our privacy practices relating to Financial Services information and the choices you can make about how we share your information can be found in our privacy policy. You can manage how we share your personal information by sending a opt out, deletion, or change email here.
If we make any material changes to our Privacy Policy as relates to Financial Services, we will provide our current Financial Services customers with revised notices that describe our new policies and procedures that apply to them.

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