California Consumer Privacy Policy

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This Privacy Notice for California Residents applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”), and supplements the information contained in the AllianceOne Receivables Management, Inc. (“AllianceOne”) Privacy Policy. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

1. Information We Collect About You
We may collect and use the following personal information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer, device, or household (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information does not include:

• Publicly available information from government records.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

2. How Your Personal Information is Collected
We collect most of this personal information directly from our clients whom we provide services to, as well as from you by telephone, written correspondence through the mail, text, email, or fax, by viewing your public social media/network pages, or other information available online. However, we may also collect information:

• From publicly available sources (e.g., property records or court records);
• From our service providers (e.g., letter vendors, skip tracing vendors, payment processing vendors, call analytics vendors, and/or electronic signature service provider);
• Directly from a third party (e.g., third parties contacted during skip tracing activities pursuant to 16 U.S.C. §1692b, such as your friends, neighbors, relatives, and/or employer);
• From a third party with your consent (e.g., your authorized representative and/or attorney); and
• Directly and indirectly from activity on our website (www.allianceoneinc.com). For example, from submissions through our website portal or website usage details collected automatically.

3. Why We Use Your Personal Information
We may use or disclose your personal information for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in a job application, we will use that information to manage your application and evaluate your qualifications for a job or if you share your personal information to make a payment, we will use that information to process your payment.
• Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
• To provide you with information, products or services that you request from us.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Debugging to identify and repair errors that impair existing intended functionality.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

4. Who We Share Your Personal Information With
We disclose your personal information for a business purpose to the following categories of third parties:

• Our affiliates.
• Service providers we use to help deliver our services, such as payment service providers.
• Other third parties we use to help us run our business, such as marketing agencies or website hosts.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you, including third-party payment providers.
• Our insurers and brokers; and
• Our bank(s).

In the preceding twelve (12) months, we have not sold any personal information.

5. Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. You have the right under the CCPA and certain other privacy and data protection laws, as applicable, to exercise free of charge. This section describes your rights and explains how to exercise those rights.

a. Disclosure of Personal Information We Collect About You
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources from which the personal information is collected.
• Our business or commercial purpose for collecting or selling personal information.
• The categories of third parties with whom we share personal information, if any.
• The specific pieces of personal information we collected about you (also called a data portability request).

Please note that we are not required to:

• Retain any 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 retained;
• Re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
• Provide the personal information to you more than twice in a twelve (12)-month period.

b. Disclosure of Personal Information Sold or Used for a Business Purpose
In connection with any personal information that we may sell or disclose to a third party for a business purpose, you have the right to know:

• The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
• The categories of personal information that we disclosed about you for a business purpose.

c. Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
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, provided we have obtained your informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of your personal information that are compatible with the context in which you provided it.

d. Protection Against Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate, or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to you by your personal information.

6. How to Exercise Your Rights
To exercise the access, data portability, and deletion rights described herein, please submit a verifiable consumer request to us by either:

• Calling us toll-free at 800-858-4472;
• Visiting www.allianceoneinc.com/contact-us/ and selecting “I have a privacy concern” from the dropdown menu; or
• Email us at privacy@allianceoneinc.com

Please note that you may only make a data access or data portability disclosure request twice within a twelve (12)-month period.

7. Verifying Your Identity (i.e., verifiable consumer request)
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
If you choose to contact us directly by email, phone, or via our website, you will need to provide us with:

• Sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative (e.g., your full name, address, and AllianceOne account number);
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card statement); and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

8. Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we may inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we may deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12)-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 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. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

9. Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

10. Contact Information
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 800-858-4472
Website: www.allianceoneinc.com
Email: privacy@allianceoneinc.com
Postal Address:
AllianceOne Receivables Management, Inc.
Attn: Privacy Inquiry
3043 Walton Road
Suite 201
Plymouth Meeting, PA 19462

This California Consumer Privacy Policy is effective January 1, 2020. Any previous version of this policy is superseded going forward by this version.