Privacy Policy and State and Local Disclosures

Privacy Policy and State and Local Disclosures

UNIFUND PRIVACY NOTICE

This Privacy Policy discloses the privacy practices of Unifund CCR Partners, Unifund CCR, LLC, and Unifund Corporation (also referred to collectively as “Unifund”, “us,” or “we”). We understand that your privacy is important to you and are committed to protecting your privacy. This Privacy Policy explains what information we collect, how we use that information, and how we protect your privacy.

Unifund’s website, located at www.unifund.com (its “website”), is not intended for individuals less than the age of eighteen. Unifund does not knowingly collect data relating to individuals less than the age of eighteen.

Nothing in this Privacy Notice is intended to contradict your rights under the Fair Debt Collection Practices Act. As required by the FDCPA, Unifund will not disclose any information to third parties without your express permission.

Questions, comments, and complaints about Unifund’s data practices can be submitted to:

Unifund CCR Partners
PO Box 42121
Cincinnati, OH 45242-0121
Toll free: (888) 384-8134

Information We Collect
Nonpublic Personal Information.  Nonpublic personal information is defined as any personally identifiable financial information provided by the consumer to obtain a financial product; or resulting from transactions with that product; or information a financial institution obtains about the consumer in connection with that product (e.g., credit bureau information). For example: Social Security number; driver’s license numbers (in some states); place of employment or work telephone number; non-listed home phone; where the consumer banks; details about the particular account. Other examples of nonpublic personal information include: account balances; payment histories; transaction history; or any information that discloses that this individual has a financial relationship with the institution.

Public Personal Information.  Public personal information (or information which a financial institution reasonably believes is publicly available) can be disseminated without restriction under the Act and regulations; this type of information includes:

Motor vehicle ownership, drivers’ license information (in some states) and real estate ownership data, which have been, derived from public records; addresses and phone numbers from paper or electronic. Information obtained from any website which can be accessed by anyone without restriction (paying a fee for this information is not a restriction). Presumably, and the regulations do not mention it, information about a debtor that is publicly available in court records (e.g., banks successfully garnished for a debtor; employers successfully garnished for a debtor; existence of a debtor’s Chapter 7 or Chapter 13 filings) are examples of “public personal information” not subject to this regulatory regime.

However, we cannot disclose data about the debt or financial relationship to third parties unless that transaction is a matter of public record (for example, real estate mortgages).

These “public” data can be exchanged with third parties without privacy notices because the data is not “nonpublic personal information.” HOWEVER, as a “debt collector” under the Fair Debt Collection Practices Act (“FDCPA”), there are other restrictions on disclosure of any data about a debtor and his/her debt that are NOT supplanted or superseded by the privacy regulations. Familiarize yourself with the FDCPA and consult legal counsel before you transfer information about a debtor and his/her debt to a third party.

We may have collected the following categories of personal information from consumers within the last 12 months.  Inclusion of a category indicates that we may collect some information in that category. It does not mean that we collect all information listed in that category in all situations.

Categories of Personal Information Examples of Specific Types of Personal Information Collected Collected Purpose
A. Identifiers A real name, alias, postal address, email address, telephone numbers, account number, Social Security number, date of birth, or other similar identifiers. Yes (a) Necessary to provide the services

(b)Necessary to comply with a legal obligation

(c) Necessary for our legitimate business interests

(d) Prevent fraud

B. Personal Information categories listed in California Customer Records Statute (Cal. Civ. Code §1798.80(e)) A name, signature, Social Security number, address, telephone number, employment, employment history, bank account number, credit card number, debit card number, Some personal information included in this category may overlap with other categories. Yes (a) Necessary to provide the services

(b)Necessary to comply with a legal obligation

(c) Necessary for our legitimate business interests

(d) Prevent fraud

C. Protected classification characteristics under California or Federal law Age (40 years or older), veteran or military status. Yes (a) Necessary to provide the services

(b)Necessary to comply with a legal obligation

(c) Necessary for our legitimate business interests

D. Commercial information Records of personal property, products or services purchased. Yes (a) Necessary to provide the services

(b)Necessary to comply with a legal obligation

(c) Necessary for our legitimate business interests

E. Professional or employment-related information Current or past job history. Yes (a) Necessary to provide the services

(b)Necessary to comply with a legal obligation

(c) Necessary for our legitimate business interests

F. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Yes (a) Necessary to provide the services

(b)Necessary to comply with a legal obligation

(c) Necessary for our legitimate business interests

G. Sensitive Personal Information Government-issued identifying numbers, such as a driver’s license, passport or social security number, financial account details that allow access to an account, such as a credit card number and access code, genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs, union membership, contents of mail email or text messages, biometric data related to your unique identification. Yes (a) Necessary to provide the services

(b)Maintain and service your account

(c) Process payments

(d) Ensure security and integrity regarding the use of such personal information

(e) Verify or maintain the safety and quality of the services

(f) Necessary to comply with a legal obligation

(g) Necessary for our legitimate business interests

How We Use Your Information
Personal information is collected for the purpose of debt recovery in a lawful manner remains part of our records until we determine the information is no longer needed, or we are required by law to delete such information. We will collect the minimum amount of data necessary to collect a debt.  We may also use personal information that you provide to us to fulfill or meet the reason you provided such information.  Your personal information will also be used to perform services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, verifying customer information, processing payments, providing analytic services, or providing similar services.  We may also use your information to respond to law enforcement requests and as otherwise permitted by applicable law, court order, or governmental regulations, to ensure security and integrity of the personal information, and to prevent fraud.

Sensitive personal information is collected only as necessary to perform our services, process payments, maintain or service your account, to ensure security and integrity regarding the use of such personal information, and to verify or maintain the safety and quality of the Services.  Sensitive personal information is not collected with the purpose of inferring characteristics about you.

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.

We do not sell and will not sell your personal information.

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

  • From publicly accessible sources (e.g., property records or court records);
  • From your transactions with us;
  • From our service providers (e.g., letter vendor, location vendors, payment processing vendors, and/or electronic signature service provider);
  • Directly from a third party (e.g., third parties contacted during location activities pursuant to 15 U.S.C. §1692b, such as your friends, neighbors, relatives, and/or employer);
  • Consumer reporting agencies (CRAs)
  • From a third party with your consent (e.g., your authorized representative and/or attorney); and
  • From activity on our website.

How We Share Your Information
Unifund may share personally identifiable information it collects with its employees who need to know that information to provide collection services with respect to your account. Except as provided below, Unifund will not share or disclose any personally identifiable information with any unaffiliated third-party company or marketing group without your express permission. Unifund may share your personal information with third parties to the extent it is reasonably necessary to manage or service your account, verify employment, determine location, process payment, fulfill a transaction, provide customer service, or as otherwise authorized by law.   Further, Unifund may disclose personally identifiable information (i) to another entity with which Unifund enters or reasonably may enter into a corporate transaction, such as, for example, a merger, consolidation, acquisition, or asset purchase, (ii) to a third party pursuant to a subpoena, court order, or other form of legal process or in response to a request by or on behalf of any local, state, federal, or other government agency, department, or body, whether or not pursuant to a subpoena, court order, or other form of legal process, or in connection with litigation brought against, or on behalf of, Unifund, where appropriate, (iii) to a third party if determined by Unifund in its sole judgment that such disclosure is appropriate to protect the life, health, or property of Unifund or any other person or entity, all in compliance with applicable law, (iv) to third parties as authorized or designated by you, or (v) to conduct any other legitimate business activity not otherwise prohibited by law. The foregoing is not intended to obviate or displace any legal obligations or duties applicable to Unifund.

How We Use Cookies
Unifund may collect certain computer and browser information through automated technologies such as cookies and web beacons when you visit our website. Cookies are small pieces of (text) information that are sent to your browser when you visit the website to identify the browser or to store information or settings in the browser. They are then stored on the hard disk or in the memory of your equipment. The browser can send this information back on your next visit to the website. The cookies placed via the website cannot damage your equipment or the files stored on it. Web beacons (also known as internet tags, pixel tags, or clear GIFs) link web pages to web servers and their cookies may be used to transmit information collected back to a web server.

Sharing your information with Consumer Reporting Agencies
Consumer Reporting Agencies (CRAs) collect and maintain information on consumer and business credit profiles on behalf of organizations in the United States. We may share information about you with CRAs and may carry out periodic searches with them to verify your identity or manage your account. Details of your account(s) with us may be sent to CRAs and recorded by them. This information may be supplied by CRAs and may be used and searched by us and other organizations, such as debt collection agencies, in order to:

  • consider applications for credit and credit related services;
  • locate debtors and recover debts; and
  • manage your accounts.

Unifund may furnish account information to Experian, Equifax, and TransUnion. You have a right to obtain an annual copy of your credit file from CRAs by visiting https://www.annualcreditreport.com. Your Choices: Unifund offers you certain choices in connection with the personal data it collects from you, including: Your Unifund Account: You may review, update and correct your contact information, including your telephone number and email address, after logging in to the website, or by calling our office. Your Payments: You can elect not to utilize the payment portal of Unifund’s website and not to make payments via credit card or check. If you have any questions regarding any of these choices, please contact Unifund.

Our Contact Address is:
Unifund CCR Partners PO Box 42121 Cincinnati, OH 45242-0121 Toll free: (888) 384-8134

How Long We Keep Your Information
Unifund will retain until we determine the information is no longer needed, or as otherwise required by law. Unifund thereafter deletes or anonymizes such information in accordance with applicable laws.

How We Protect Information
Unifund has implemented physical, electronic, and procedural security safeguards to protect against the unauthorized release of or access to personal information. We employ internal and external system safeguards designed to protect confidentiality and security of personal information. We restrict access to nonpublic personal information about you to those employees determined by us to need to know the information. E-mail posted or sent to Unifund may not be secure against interception by unauthorized individuals. To protect against interception by unauthorized individuals, or because we cannot verify your identity, we may be unable to respond to e-mail requests concerning accounts placed for collection unless you have requested or authorized us to do so. If any questions arise about security, please contact Unifund using the information provided above.

Your Legal Rights

  • The right to access personal information – You have the right to submit a verifiable request for access to your personal information that we collected about you, subject to certain exceptions. This may include the categories and specific pieces of information collected, the sources of that information and the business or commercial purpose for the collection or disclosure of that information.
  • The right to request correction of personal data we hold about you – This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • The right to request deletion of personal information – You have the right to request that we delete your personal information, however, state and federal law may prohibit us from deleting personal information, which Unifund will disclose to you. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
  • The right to object to processing of your personal data – Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms, you have the right to object to processing of such data. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • The right to request restriction of processing of your personal data – This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • The right to request the transfer of your personal data to you or to a third party – We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • The right to withdraw consent at any time where we are relying on consent to process your personal data – however, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • Rights related to automated decision making and profiling – ‘Automated Decision Making’ refers to credit decisions regarding consumer lending terms or conditions predicated solely on the creditor’s automated processing of personal data. This means credit decisions may be made by a creditor, for example, using software code or an algorithm which does not require human intervention. We do not extend credit or make credit decisions for any person and we do not use your personal data as part of any such automated decision making or profiling when servicing your account.
  • The right to non-discrimination – We will not discriminate against you if you exercise any of these rights.
  • The right to an authorized agent – You can designate an authorized agent to make any of these requests by providing your express written authorization. We must be able to verify your identity and the authorization must include the authorized agent’s name, address, telephone number, and email address (for providing the personal information collected or to respond to a request for deletion).

We must be able to verify your identity and the authorization must include the authorized agent’s name, address, telephone number, and email address (for providing the personal information collected or to respond to a request for deletion). To prevent anyone other than you, or your authorized agent, from exercising the right to know or the right to delete with respect to your personal information, we follow procedures to verify your, or your agent’s, identity. These procedures seek to confirm that the person making a request is the person about whom we have collected personal information or that person’s authorized agent. The verification procedures involve matching data points that you provide with your request against information about you we already have in our records and that we have determined to be reliable for purposes of verifying your identity. We will use information you provide in your completed request form to verify your identity, and we may request additional information if necessary to complete the verification process.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.


If you would like to appeal of our decision with respect to your exercise of the above rights, an appeal may be sent to the data controller using the same process for submitting initial requests. A response to an appeal may take up to 60 days, at which time Unifund shall respond to your request.

If you wish to exercise any of these rights, please contact Unifund by doing one of the following:

  1. By mailing a request to:
    Unifund CCR Partners,
    PO Box 42121,
    Cincinnati, OH 45242-0121
  2. Contacting us toll free at (888) 384-8134
  3. Interactive webform

If you choose to contact us directly by phone or in writing, you will need to provide us with:

  • Enough information to identify you [e.g., your full name, address, last four digits of your Social Security number, date of birth, and/or account number]; 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.

Links to Other Websites
Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. We are not responsible for the protection and privacy of any information that you provide while visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question. 

Privacy Notice Changes
Unifund may change this Privacy Notice at any time. Notice of any new or revised Privacy Notice, as well as the location of the new or revised statement, will be posted on the website after the change. It is the obligation of users visiting the website before the change to learn of changes to the Privacy Notice since their last visit.

STATE DISCLOSURES

For California Residents Only:
The State Rosenthal Fair Debt Collection Practices Act and the federal Fair Debt Collection Practices Act require that, except under unusual circumstances, collectors may not contact you before 8 a.m. or after 9 p.m. They may not harass you by using threats of violence or arrest or by using obscene language. Collectors may not use false or misleading statements or call you at work if they know or have reason to know that you may not receive personal calls at work. For the most part, collectors may not tell another person, other than your attorney or spouse, about your debt. Collectors may contact another person to confirm your location or enforce a judgment. For more information about debt collection activities, you may contact the Federal Trade Commission at 1-877-FTC-HELP or www.ftc.gov

For Colorado Residents Only:
A consumer has the right to request in writing that a debt collector or collection agency cease further communication with a consumer. A written request to cease communication will not prohibit the debt collector or collection agency from taking any action authorized by law to collect the debt. Our local office address is: (1) Unifund CCR Partners – 13111 E. Briarwood Ave. #340, Englewood, CO 80112. Our local phone number is (303)768-9099; and (2) Unifund CCR, LLC – 80 Garden Center, Suite 3, Englewood, CO 80112. Our local phone number is (303)920-4763. FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COAG.GOV/CAR 

For Maryland Residents Only:
The Commissioner of Financial Regulation for the State of Maryland will accept all questions or complaints from Maryland residents regarding the below listed entities at 500 N Calvert St #402, Baltimore, MD 21202, toll–free 888-784-0136. Licensee information may be found in the Nationwide Multistate Licensing System (NMLS): https://www.nmlsconsumeraccess.org/.

Entity Name License # NMLS #
 DISTRESSED ASSET PORTFOLIO I, LLC 6031 1399506
DISTRESSED ASSET PORTFOLIO II, LLC 6215 1404451
DISTRESSED ASSET PORTFOLIO III, LLC 6202 1404461
DISTRESSED ASSET PORTFOLIO IV, LLC 6275 1400025
FIRST RESOLUTION INVESTMENT CORPORATION 5931 1265763
PILOT RECEIVABLES MANAGEMENT, LLC 6014 1400158
Unifund CCR Partners 4456 1115596
UNIFUND CCR, LLC 6184 4456 917948
UNIFUND PORTFOLIO A, LLC 5799 1400167
Unipac IX, LLC 5802 1400173
Unipac VI, LLC 5801 1400176

For Massachusetts Residents Only:
NOTICE OF IMPORTANT RIGHTS
YOU HAVE THE RIGHT TO MAKE A WRITTEN OR ORAL REQUEST THAT TELEPHONE CALLS REGARDING YOUR DEBT NOT BE MADE TO YOU AT YOUR PLACE OF EMPLOYMENT. ANY SUCH ORAL REQUEST WILL BE VALID FOR ONLY TEN DAYS UNLESS YOU PROVIDE WRITTEN CONFIRMATION OF THE REQUEST POSTMARKED OR DELIVERED WITHIN SEVEN DAYS OF SUCH REQUEST. YOU MAY TERMINATE THIS REQUEST BY WRITING TO THE DEBT COLLECTOR. Mass. Regs. Code tit. 940 § 7.04(1)(i) (West, WESTLAW through June 8, 2012).

For Minnesota Residents Only:
Unifund CCR Partners and Unifund CCR, LLC only This collection agency is licensed by the Minnesota Department of Commerce. 

For New York Residents Only:
Unifund CCR Partners – New York City Department of Consumer Affairs license number: 1251678. Unifund CCR, LLC – New York City Department of Consumer Affairs license number: 1419944.

For New York City, New York Residents Only:
To better serve you, please advise us if you have any language preference other than English.  At this time, we have the following language access services available to you upon request: (1) Spanish speaking interpreters, and (2) translation of our written communications into Spanish.  In addition, a translation and description of commonly-used debt collection terms is available in multiple languages on New York City’s Department of Consumer Affairs website at https://www1.nyc.gov/site/dca/consumers/Glossary-of-Common-Debt-Collection-Terms.page.

For North Carolina Residents Only:
Unifund CCR Partners – NC License #119500731 – 10625 Techwoods Circle, Cincinnati, OH 45242 Unifund CCR, LLC – NC License #119505252 – 10625 Techwoods Circle, Cincinnati, OH 45242

For South Carolina Residents Only:
South Carolina Supervised Lenders License Numbers: SL-917948 and SLW1-917948. You can review and download the South Carolina Rights and Responsibilities document.

For Tennessee Residents Only:
Unifund CCR Partners is licensed by the Tennessee Collection Services Board of the Department of Commerce and Insurance. License Number: 975. Unifund CCR, LLC is licensed by the Tennessee Collection Services Board of the Department of Commerce and Insurance. License Number: 1323.