DebtCommand.com.com and its subsidiaries and
personal privacy seriously. In the course of providing you with products and
services, we may collect certain information from or about you. We are
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
Policy, you should not visit, access, or use, or provide information to us in
connection with, the DebtCommand.com Services.
1. DEFINED TERMS
(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.
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).
(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.
(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
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
(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.
(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:
(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
(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.
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
13. CONTACT INFORMATION.
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.