As you may well know, Congress has passed the Gramm-Leach-Bliley Act. The GLB deals with how financial institutions treat nonpublic personal financial information. Joseph, Mann & Creed hereafter known as “JMC” understands how important your privacy is to you. This is why we, JMC strongly believe in protecting the confidentiality and security of information we obtain about you. JMC privacy policies and procedures apply only to our company, not to third parties who may handle your personal information.
The Fair Debt Collection Practices Act provides that a debt collector may not use any false, deceptive, or misleading representation or means in connection with the collection of debt. Section 807 of the Fair Debt Collection Practices Act provides that "false, deceptive, or misleading representation" includes the failure to disclose in the initial oral or written communication with the consumer that "the debt collector is attempting to collect a
debt and that any information obtained will be used for that purpose", and the failure to disclose in subsequent communications that "the communication is from a debt collector". This is referred to as the "Mini-Miranda" Requirement Our internal policy on the Mini-Miranda Requirement exceeds the minimum standards required by law; our policy is that a collector must give the Mini-Miranda to a consumer on each contact made. Collectors are trained to give the Mini-Miranda once they have identified that the person they are speaking with is the correct debtor and prior to discussing the debt or any demand for payment.
Choice and Consent
JMC collects only personal information essential to securing payment of our clients’ receivables. Failure to provide the minimum personal information required to complete a payment may result in further collection efforts from JMC or our clients. By providing JMC with personal information, you are giving JMC implicit consent to use this information for
further collections efforts. JMC employees may request your explicit consent prior to collecting sensitive personal information from you. If personal information is to be used for purposes not previously identified in this privacy notice you will be notified. All payment information is protected in accordance with PCI DSS Security Standards and explicit consent is required prior to processing any credit card payments.
Confidential information entrusted to JMC will be secured from unauthorized viewing, accidental distribution, and accidental loss. Confidential information is received in both paper and electronic form. Account information is not purged from our database. Your personal information is kept electronically and any paper containing personal information is disposed of securely. JMC maintains compliance with SSAE 16 security principles such as:
Parties To Whom We Disclose Information
- Employees are authorized to access personal information based on job responsibilities.
- Authentication is used to prevent
unauthorized access to personal information stored electronically.
- JMC provides secure processing areas for mail collection, mail opening, payment posting, reconciliation and remittances.
- Physical security is maintained over personal information stored in hard copy form, and encryption is used to prevent unauthorized access to personal information sent over the internet.
- Additional security safeguards are applied to sensitive information.
Joseph, Mann & Creed does not sell, release, or distribute any nonpublic information obtained except as required or permitted by law. Personal information is disclosed to third parties only for the purposes identified in this notice and for which you have provided implicit or explicit consent unless a law or regulation specifically allows or requires otherwise. Third parties may include our clients, vendors, and credit card processors with whom we have agreements to protect your personal information in a manner
Access to Your Information
JMC collects information fairly and lawfully from others, such as credit bureaus, affiliates, or other companies. JMC may collect information regarding your whereabouts or financial information from third- party sources. You have the right to obtain certain items of information that we have collected about you. You also have the right to request correction of information if you feel it is not accurate. These requests must be made in writing. If we agree, we will correct our records and may notify our client. If we do not agree, we will be sure to communicate this to you.
Inquiry, Complaint and Dispute Process
Any inquiries, complaints or disputes should be directed to our corporate compliance officer in writing to the address listed at the end of this policy.
JMC Online Privacy
As is true of most web sites, our servers automatically collect and store certain technical information when you visit our web sites, including information such as the internet protocol (IP) address of the device you use to connect to the Internet, browser type, internet service provider (ISP), the web site you came from and exited to, operating system, date/time stamp, and pages visited. In addition, we or our third-party service providers may place and read session and/or persistent "cookies" on the computer you are using, and use other technologies such as Web beacons, clear GIFs, tracking pixels and tags, when you visit our websites or open our email. JMC and our service providers may use information from our server logs, cookies and other technologies, in combination with information you provide, transaction information, and information that we or they collect from others, to process your transactions, to fulfill legal and regulatory requirements, and as otherwise
information to them.
To change how Joseph, Mann, and Creed communicate with you, please contact your collection representative, write to our mailing address at 8948 Canyon Falls Blvd. Suite 200, Twinsburg, Ohio 44087, or email our compliance department at email@example.com
For further information or questions, please feel free to contact us by phone at (216)-831-5626 or in writing at 8948 Canyon Falls Blvd. Suite 200, Twinsburg, Ohio 44087.